PRIVACY POLICY

LAST UPDATED: 7/12/2020


Our Policy


This Privacy Policy describes the data protection practices of Clesson Co., LTD. (“CLESSON,”, “we,” “us,”, or “our”). This Privacy Policy applies to information that we collect and use about you when you access or use the CLESSON website, mobile application, or other online or mobile service that links to or otherwise presents this Privacy Policy to you. We refer to these products and services collectively as the “Services.”


We at CLESSON work hard to provide high quality online and mobile musical educational contents. With so many individuals logging into our sites, we understand the importance of your privacy. Maintaining your privacy and the trust of our users is important to us. CLESSON may store, process, and, under certain circumstances, share your information as described in this Privacy Policy.


PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVATE POLICY, PLEASE DO NOT USE THE SERVICES.


This Privacy Policy contains the following sections:


  1. INFORMATION WE COLLECT

  2. HOW WE USE YOUR INFORMATION

  3. WHEN INFORMATION IS SHARED

  4. COOKIES AND SIMILAR TECHNOLOGIES

  5. YOUR CHOICES

  6. CHILDREN’S PRIVACY

  7. HOW WE SECURE AND HOW LONG WE STORE INFORMATION

  8. INTERNATIONAL DATA TRANSFERS

  9. CHANGES TO THIS PRIVACY POLICY

  10. CONTACT US


ADDENDUM

PRIVACY NOTICE FOR RESIDENTS OF CERTAIN U.S. STATES




  1. INFORMATION WE COLLECT


We collect information about you through the means discussed below. Please note that we need certain types of information so that we can provide the Services to you. If you do not provide us with such information, or ask us to delete it, you may no longer be able to access or use our Services.


  1. Information You Provide to Us


We collect variety of information that you provide directly to us. For example, we collect information from you through:

  • The Services you use or processing your orders

  • Requests or questions you submit to us via online forms, email, or otherwise

  • Your participation in contests, or surveys

  • Any reviews that you submit about the Services

  • Account registration and administration of your account

  • Uploads or posts to the Services

  • Requests for customer support and technical assistance


Information about you. While parts of the Services may not require you to provide any information that can directly identify you by name (such as if you choose to browse the website without logging in), the specific types of information we collect will depend upon the Services you use, how you use them, and the information you choose to provide. The types of data we collect directly from you includes:


  • Contact information, including name, phone number, mailing address, and email address.

  • Payment information, which our payment processors collect when you make purchases.

  • Correspondence you send to us.

  • Demographic information, including your age, gender and country.

  • Classes in which you enroll

  • Any other information you choose to directly provide to us in connection with your use of the Services


Information about others. If you request that your purchase be provided to someone other than yourself (such as a gift recipient), we use the information you provide about the other person to fulfill the shipment.


  1. Information We Collect Through Automated Means


When you use our Services, we collect certain information as described in this Section. As discussed further below, we and our service providers (which are third party companies that work on our behalf) may use a variety of technologies, including cookies and similar tools, to assist in collecting this information.


Websites. When you use our website, we collect and analyze information such as your IP address, browser types, browser language, operating system, software and hardware attributes (including device IDs) referring and exit pages and URLs, the number of clicks, pages viewed and the order of those pages, date and time of use, content watched, total minutes watched, error logs, and other similar information about how you use the website.


Mobile Applications. When you use a CLESSON mobile application or software (“app”), we automatically receive certain information about the mobile phone, tablet, or computer used to access the app, including device identifiers, IP address, operating system, version, Internet service provider, browser type, domain name and other similar information, whether and when you update the app, date and time of use, content watched, total minutes watched, error logs, and other similar information about how you use the app.


Location Information. When you use the Services, we and our service providers may automatically collect general location information (e.g. IP address, city/state and/or postal code associated with an IP address) from your computer or mobile phone.


  1. Information We Collect from Social Media and Other Content Platforms


If you access the Services through a third-party connection or log-in (e.g., through a social network like Facebook or Twitter), you may allow us to have access to and store certain information from your social network profile. This can include your name, gender, profile picture, your “likes” and check-ins, and your list of friends, depending on your settings on such services. If you do not wish to have this information shared, do not use a social networking connection to access the Services. For a description of how social networking sites handle your information, please refer to their privacy policies and terms of use, which may permit you to modify your privacy settings. You may also have the option of posting your Service activities to Social Networking Services when you access content through the Services (for example, you may post to Facebook that you enrolled in a class on the Service); you acknowledge that if you choose to use this feature, your friends, followers and subscribers on any Social Networking Services you have enabled will be able to view such activity.


  1. Information We Collect from Others


We may receive additional information such as demographic and statistical information from third parties, such as business partners, marketers, researchers, analysts, and other parties that we may attribute to you based on your assignment to certain statistical groups. We use this information to supplement the information that we collect directly from you in order to derive your possible interests and to provide more relevant experiences for you and improve our products, analytics, and advertising.


  1. HOW WE USE INFORMATION


We may use, record, systematize, store, update or modify, retrieve, delete or otherwise process your information for the following purposes, using manual or automated means:


  • Complete a purchase or provide the Services you have requested, including invoicing and accounting

  • Respond to your request for information and provide you with more effective and efficient customer service

  • Provide you with updates and information about classes in which you have enrolled

  • Contact you by email, postal mail, or phone regarding CLESSON and third-party products, services, surveys, research studies, promotions, special events and other subjects that we think may be of interest to you

  • Customize the advertising and content you see on the Services

  • Help us better understand your interests and needs, and improve the Services, including through research and reports, and test and create new products, features, and services

  • Secure our websites and applications, and resolve app crashes and other issues being reported

  • Comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others

  • Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others.


Combined Information. For the purposes discussed in this Privacy Policy, we may combine the information that we collect through the Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Policy.


Aggregate/Anonymous Data. We may aggregate and/or anonymized any information collected through the Services so that such information can no longer be linked to you or your device. We may use such information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors.


  1. WHEN INFORMATION IS SHARED


We limit when we share the information we collect to the following circumstances:


Affiliates and Subsidiaries. We may share information we collect within CLESSON to deliver products and services to you, ensure a consistent level of service, and enhance our products, services, and your customer experience.


Business Partners. We may share information with third-party partners and service providers, including payment processing and gateway companies, platform services, customer support services, cloud storage and hosting providers, social media companies (who may collect information when you use the Services or when you connect the Services to your social media accounts) and analytics and advertising companies, to help us provide and improve the Services and operate our business. For more information about these business partners, please contact us.


Other Users. Your profile, including your username and the picture that you may provide, and information about your activities on the Services may be visible to other users of the Services or third-party sites and services. For example, your profile information may be viewed by other users of the Services and, if you choose to link to social media sites like Facebook, viewed by users of such sites.


Legal Purposes. We may provide your information to third parties when we believe that doing so is required by law or to cooperate with regulators or law enforcement authorities. We may disclose your information in order to protect the rights or property of CLESSON, and others, or when we believe that there is an emergency that poses a threat to the health or safety of you, another person, or the public.


Corporate Transaction. If CLESSON is involved in a corporate transaction, such as a merger, acquisition by another company, asset sale, or in the unlikely event of bankruptcy, we may transfer your information to the successor organization in such transaction in accordance with applicable law.


With Your Consent. We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent.


  1. COOKIES AND SIMILAR TECHNOLIGIES


When you use the Services or interact with emails from us, we and our third-party business partners may collect and store information about your use of our Services using cookies, pixel tags, local storage, and similar technologies.


Cookies are small files that are automatically generated when you visit a website and are stored on your device. Pixel tags are very small images or small pieces of data embedded in images, also known as “web beacons” or “clear GIFs,” that can recognize cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your device. Local storage is similar to a cookie except that it can store larger amounts of information and can be stored elsewhere on your device.


We use cookies and similar technologies (collectively, “cookies”) for the following functions and purposes:


Function

Purpose

Analytics and Research

We use analytics and research cookies to collect information about how visitors use our Services, including the total number of people that use our Services and the types of devices they use. We may use the information to compile reports of aggregated and de-identified information and to help make improvements to the Services.

Authentication

These cookies help us to identify our users so that when you are signed in, you can enjoy the Services and features fully. These cookies are essential and cannot be blocked if you wish to use the Services.

Service Features and Performance

We use feature-tracking cookies to collect information about how our Services are performing. We may use the information to compile reports and to help make improvements to the Services.

Advertising

We use advertising cookies to customize the advertising that is shown to you on the Services and on third-party websites and services.


We allow third parties, including our analytics providers, advertising networks, and other advertising service providers, to collect information about your use of the Services across your applications and your different devices using cookies and similar technologies. These third parties may use this information to display advertisements on our Services and elsewhere online across different sites and services tailored to your interests, preferences, and characteristics. You can control the use and disclosure of the information for such purposes through Your Choices.


YOU CONSENT TO THE USE OF NON-ESSENTIAL COOKIES AND OTHER TECHNOLOGICAL MEANS AS IDENTIFIED IN THIS PRIVACY POLICY WITHOUT PREJUDICE TO ANY RIGHTS YOU MAY HAVE UNDER APPLICABLE LAW TO LATER REFUSE OUR USE.


  1. YOUR CHOICES


CLESSON provides you with a variety of choices to control the use and sharing of your information, including:


Email Communications. You may opt out of receiving commercial email messages from us by following the unsubscribe instructions provided in our emails. Please note that even if you have opted out of receiving commercial email messages, you may continue to receive messages related to your account, your transactions, and similar service-related messages.


Geolocation Information. Your device may enable you to control the collection of your precise geolocation information, and whether this information is shared with third parties, through the settings on your device. Please note that you may need to adjust multiple settings, and not just your location permissions, to opt out of providing precise location information. If you opt out of providing precise geolocation information, we may continue to derive your approximate location from your IP address and other information we may collect. For more information, please review your device settings.


Cookies and Similar Technologies. You may be able to refuse or disable cookies by adjusting your web browser settings. Because each web browser is different, please consult the instructions provided by your web browser (typically in the “help” section). Please note that you may need to take additional steps to refuse or disable local storage and similar technologies. For example, Adobe Local Shared Objects can be controlled through the instructions on Adobe’s Setting Manager page. Deleting the cookies in your browser may in some cases cancel your choices for interest-based advertising. If you choose to refuse, disable, or delete cookies and similar technologies, some of the functionality of the Services may no longer be available to you.


Do Not Track Signals and Similar Mechanisms. Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates. CLESSON currently does not take action in response to these signals.


Interest-Based Advertising. While it is not possible to turn off all advertising, you do have the ability to control whether you receive interest-based ads based on information collected or received about your online activities and interests over time and across unaffiliated sites and services and your different devices. You can opt out of receiving interest-based ads from companies that participate in self-regulatory programs such as the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), EDAA (EU), and DAAC (Canada) by following the instructions provided on their websites. If you are using a mobile app, you also may need to opt out of interest-based advertising on your mobile device or through the mobile application. For more information, check your device and mobile app settings. Please note that your opt-out choice will apply only to the browser and device you are using when you opt out.


Other Device Permissions. You may be able to adjust your privacy settings for push notifications, address book sharing, and other information or features within the Services or your device permissions. Please review the settings for the Services and your device for more information.


Data Rights and Withdrawal of Consent


The laws in your country may provide you rights to request access to, correct, restrict, port, copy, or delete your information, request that we stop processing your information or delete your account, or withdraw or change the scope of your consent. If you withdraw your consent, we will stop processing your information for such purposes, but it will not affect the processing of information previously covered by your consent. Where technologically feasible and required by applicable law, we will port your information pursuant to your reasonable request. A request to withdraw consent, restrict or stop processing your information, or delete your account or information may result in your inability to access the Services or some of its features. To exercise your rights consistent with applicable law, please contact us.


  1. CHILDREN’S PRIVACY


The Services are intended for general audiences and not for children under the age of 13. If we become aware that we have inadvertently collected “personal information” (as defined by the United States Children’s Online Privacy Protection Act) from children under the age of 13 without valid parental consent, we will take reasonable steps to delete it as soon as possible. We do not knowingly process data of EU residents under the age of 16 without parental consent. If we become aware that we have collected data from an EU resident under the age of 16 without parental consent, we will take reasonable steps to delete it as soon as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws.


  1. HOW WE SECURE AND HOW LONG WE STORE INFORMATION


We maintain reasonable and appropriate physical, electronic, organizational, and procedural safeguards to protect your information. While we take reasonable precautions against possible loss, misuse, or unauthorized access, no storage system or transmission of data over the Internet can be guaranteed to be secure. Data we collect will be retained only for so long as reasonably necessary for the purposes set out above, unless applicable law requires otherwise.


  1. INTERNATIONAL DATA TRANSFERS


Information we collect may be transferred to countries outside your home country for the purposes set out in this Privacy Policy. You understand that these countries, including Korea, Japan, and the United States, may not provide the same level of data privacy protection as the European Union/European Economic Area or your home country, and you hereby expressly consent to the transfer of your information to these countries for processing in accordance with this Privacy Policy. These transfers are essential to the provision of our Services.


  1. CHANGES TO THIS PRIVACY POLICY


We may make changes to this Privacy Policy, in which case we will notify you before such changes take effect by posting the updated policy through the Services or otherwise in accordance with applicable law. Any changes to this Privacy Policy will take effect after a reasonable time period as specified in the notice of such changes.


  1. CONTACT US


The privacy and security of your information is a top priority. If you have any questions or concerns about this Privacy Policy or our information practices, please contact the publisher for the particular CLESSON Service, which is the data controller responsible for your information:


Publisher

Contact Information

CLESSON Co., Ltd.

(06019) 110-ho, 12F, 428, Seolleung-ro, Gangnam-gu, Seoul, Republic of Korea

support@clesson.net


ADDENDUM


PRIVACY NOTICE FOR RESIDENTS OF CERTAIN U.S. STATES


Some U.S. state laws (e.g., California and Nevada) provide state residents with additional privacy rights. Please click here to learn more about such state privacy rules and whether they apply to you.


PRIVACY NOTICE FOR RESIDENTS OF CERTAIN U.S. STATES


This Privacy Notice for Residents of Certain U.S. States ("State-Specific Notice") is a part of our general Privacy Policy and incorporates it by reference. Depending on the U.S. state where you reside, you may have additional privacy rights. We provide you with relevant information and choices under these laws:


Privacy Information for California Residents

Privacy Information for Nevada Residents


PRIVACY INFORMATION FOR CALIFORNIA RESIDENTS


If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your "personal information" (as defined in the California Consumer Privacy Act ("CCPA")).


Categories of personal information we collect. Throughout our Privacy Policy, we discuss in detail how we collect, use, and share personal information about our users. Under the CCPA, we are also required to provide you with the relevant "categories" of personal information we collect. The categories we collect include:


  • Identifiers (such as real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers);

  • Commercial information (such as transaction data);

  • Financial data (such as credit card information);

  • Internet or other network or device activity (such as browsing history and information on interaction with a website, application, or advertisement);

  • Geolocation data (at an IP-based or city/state/zip level);

  • Professional or employment-related information (if volunteered in a job application);

  • Education information (if volunteered in a job application);

  • Inference data about you drawn from the data in this section (based on user profile information and classes taken);

  • Legally protected classifications (such as age and gender);

  • Physical characteristics or description (if personal photo is volunteered in a user profile); and

  • Other information that identifies or can be reasonably associated with you (e.g., information you voluntarily provide as you use the CLESSON services, such as additional profile information or user-generated content).


The sources from which the categories of personal information are collected. We collect the personal information from the following categories of sources:


  • Directly from the information you provide to us;

  • Indirectly from our affiliates, service providers, and third parties with whom you have a direct relationship; and

  • Indirectly through your interaction with a website, application, or advertisement.


Business purposes for collecting categories of personal information. We collect personal information for the various business purposes below:


  • Complete a purchase or provide the Services you have requested, including invoicing and accounting;

  • Respond to your request for information and provide you with more effective and efficient customer service;

  • Provide you with updates and information about classes in which you have enrolled;

  • Contact you by email, postal mail, or phone regarding CLESSON and third- party products, services, surveys, research studies, promotions, special events and other subjects that we think may be of interest to you;

  • Customize the advertising and content you see on the Services;

  • Help us better understand your interests and needs, and improve the Services, including through research and reports, and test and create new products, features, and services;

  • Secure our websites and applications, and resolve app crashes and other issues being reported;

  • Comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others;

  • Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others; and

  • Consider and process your job application.


Sharing of categories of personal information.

We may share personal information to accomplish the various business purposes above and as described in the section “How We Share and Disclose Your Information” and “Third Party Links and Features” in our Privacy Policy.


Your California privacy rights.

CCPA Rights Disclosure. If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:


  • Inform you about the categories of personal information we collect or disclose about you and the categories of sources of such information;

  • Inform you about the business or commercial purpose for collecting personal information and the categories of third parties with whom we share/disclose personal information (which is also disclosed in this State-Specific Notice and our Privacy Policy);

  • Provide you with the specific pieces of personal information we collect about you; and

  • Delete personal information we have about you.

Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide the Services to you. You may only make such a request twice within a twelve-month period. Requests are generally free; however, we may charge a reasonable fee or deny your request if it is manifestly unfounded, excessive, or repetitive.


To make a CCPA request, please fill out this web form, or email us at psupport@clesson.net. We will request information, which at a minimum will include your name and email address, to verify your identity. We may request additional information to verify your identity before responding to a request. Under the CCPA, you may have an authorized agent submit a request on your behalf, and we will collect certain authorization and verification information from the agent and you in such circumstances.



The CCPA further provides you with the right to receive information about the financial incentives that we offer to you, if any, and the right not to be discriminated against for exercising your rights under applicable law.


If you would like further information regarding your legal rights under California law, please contact us at psupport@clesson.net.


California Do Not Sell Notice


If you are a California resident, the California Consumer Privacy Act (“CCPA”) provides you with the right to opt out of the "sale" of your "personal information." CLESSON allows some of our advertising partners to collect certain pieces of information from our site visitors, such as device identifiers, cookies, advertising IDs, IP addresses, and usage activity, so that we and our partners can deliver ads that are more relevant to you. This type of information sharing with our advertising partners may be considered a "sale" under the CCPA. Below, we explain what information we share with our advertising partners and how you can control the information that is shared for online advertising purposes and with our partners, and important information about those choices.


Facebook Ad Preferences


Facebook offers settings that may control what information Facebook uses about you or your device activity for advertising purposes. Login to Facebook and go to Settings > Ads > Ad Settings (web) or Ad Preferences > Ad Settings (app) for more information.


Digital Advertising Alliance (“DAA”) and Network Advertising Initiative (“NAI”) Opt-Outs


The Digital Advertising Alliance (“DAA”) and the Network Advertising Initiative (“NAI”) offer tools to provide consumers with choices as to whether participating third parties can use your information to provide targeted advertising. To opt out of sharing your information with such participating third parties for targeted advertising, please use the following tools:


For Websites: The DAA CCPA Opt Out Tool, available at https://optout.privacyrights.info/?c=1, and the NAI Consumer Opt-Out Tool, available at http://optout.networkadvertising.org/?c=1.

For Mobile Applications: The DAA CCPA App Opt Out Tool, available at https://www.privacyrights.info/appchoices and the NAI App Opt-Out Tool, available at https://www.networkadvertising.org/mobile-choice.


Please Note


The DAA and NAI opt-outs described above are device- and browser-based. Because the information being shared relates to your device ID and/or browser ID, you must opt out on each device and each browser where you want your choice to apply.

Opt-outs may be stored via cookies. If you clear cookies, your opt-out will no longer be valid and you must opt out again where you want your choices to apply.

The above choices will not opt you out of the use of previously collected and shared information or all interest-based advertising (such as that conducted on other sites).

Shine the Light Disclosure. The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.


PRIVACY INFORMATION FOR NEVADA RESIDENTS

Under Nevada law, certain Nevada consumers may opt out of the sale of "personally identifiable information" for monetary consideration (as such terms are defined under Nevada law) to a person for that person to license or sell such information to additional persons. We do not engage in such activity; however, if you are a Nevada resident who has purchased services from us, you may submit a request to opt out of any potential future sales under Nevada law by contacting us at psupport@clesson.net Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.


CONTACT INFORMATION

Please feel free to contact us if you have any questions about CLESSON’s Privacy Policy or the information practices of the Services.


You may contact us as follows:

(06019) 110-ho, 12F, 428, Seolleung-ro, Gangnam-gu, Seoul, Republic of Korea

support@clesson.net