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KABBALAH CENTRE INTERNATIONAL PRIVACY POLICY
Kabbalah Centre International, Inc. (the “Centre”, “we” or “our”) is providing this policy to provide to you, when you use this Site, information as to our online practices regarding information you provide to us.
By accessing our Web site maintained at www.kabbalah.com and other websites owned by the Centre (the “Site”), you expressly consent and agree to the terms and conditions of this privacy policy, including our use and disclosure of your personal information in accordance with this Privacy Policy and the choices you have made the Site. IF YOU DO NOT AGREE, THEN PLEASE DO NOT USE OR ACCESS OUR SITE. Each time a user accesses the Site, the Privacy Policy and the Terms of Use should be reviewed because the Centre reserves the right to change them from time to time without notice. Your continued use of the Site after such changes have been made constitutes your acceptance of such changes. This policy was last updated May, 2018.
Use of the Site by Residents Outside of the United States
IF YOU ARE NOT LOCATED IN THE UNITED STATES AND WISH TO USE THE SITE, INLCLUDING, BUT NOT LIMITED TO, SUBSCRIBING TO MEMBERSHIPS AND NEWSLETTERS, MAKING PURCHASES AND DONATIONS, PLEASE EXPRESSLY AND EXPLICITLY CONFIRM YOUR CONSENT TO OUR COLLECTION OF INFORMATION ABOUT YOU WHERE INDICATED AND WHERE SUCH INFORMATION IS PROVIDED BY YOU BY CONTACTING: outsideUSAconsent@kabbalah.com.
All users of our Website should also review our “Cookie” policy.
Opt-Out, Unsubscribe
You may choose to opt out of receiving communications, such as phone calls, e-mails or mailings from the Centre, and/or if you wish to have us delete any names, email addresses, phone numbers, content or communications you send to us or the like, you may use the opt out mechanism that is provided here: click on the UNSUBSCRIBE link at the bottom of any email that has been sent to you or send by certified mail, a written opt out election to the attention of our Opt-Out Email Administrator, sending an email to: care@kabbalah.com, or by writing to our Opt-Out Email Administrator at: The Kabbalah Centre 1062. S. Robertson Blvd., Los Angeles, CA 90035.
California Residents – Your Privacy Rights
Pursuant to Section 1798.83 of the California Civil Code, residents of California can obtain certain information about the types of personally-identifiable information that companies with whom they have an established business relationship have shared with third parties for direct marketing purposes during the preceding calendar year. In particular, the law provides that companies must inform consumers about the categories of personally-identifiable information that have been shared with third parties, the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. All requests in writing for this information should be sent to the attention of our Data Privacy Manager by sending an email to: DPM@kabbalah.com, or by writing to our Data Privacy Manager at: The Kabbalah Centre, 1062 S. Robertson Blvd., Los Angeles, CA 90035. NOTE: the Centre does not disclose your personally-identifiable information to third parties for direct marketing purposes.
The Centre provides you with a cost-free means to opt-out of such sharing, which you can accomplish by using the opt-out link described above in all emails, or by sending a written opt out election to the attention of our Data Privacy Manager by sending an email to: DPM@kabbalah.com, or by writing to our Data Privacy Manager at: The Kabbalah Centre, 1062 S. Robertson Blvd., Los Angeles, CA 90035.
California Do Not Track Disclosures
We do track Site users to provide targeted marketing communications about Centre activities, and therefore, we do respond to Do Not Track (or DNT) signals.
Personal Information Collected
Visitors to our Site can access the Site’s home page and browse the Site without disclosing any personally identifiable information depending on your privacy settings. See our “cookie” policy below. We may track information provided to us by your browser, including the Web site you came from (known as the "referring URL"), the type of browser you use, the time and date of access, and other information that does not personally identify you.
We may also collect the following information (your “Personal Data”):
(a) Your name;
(b) Your email address, mailing address, email address, telephone and other contact details;
(c) Your device’s IP address;
(d) Your participation and attendance at our services, classes and events;
(e) Payment information (see also the privacy policy of our payment processor);
(f) Records of your communication with us (including your communication with your teacher(s));
(g) Your opinions, beliefs and other information you choose to provide when you participate in our classes or contribute to online message boards or forums we provide;
(h) Information about your visits to our website (see 'Cookies' below).
Please also note that some of the Personal Data you supply and that we process may include what is known as 'sensitive' data about you, for example, if you post information on the Site regarding your ethnic origin or political, philosophical and religious beliefs.
If you do not provide us with specific non-sensitive Personal Data when requested, we may not be able to register you as a student, respond to a query or otherwise provide you with our classes, events or products.
Further to the extent that you post “User Content” (as defined in the Terms of Use), and you identify yourself in your post, you thereby authorize us to use your name, and any other personal information you include with your User Content as further detailed in the Terms of Use. Please be aware that any information including, without limitation, User Content that you post to the Site may be accessible by other users of the Site. Please be sure that any such information is information that you are comfortable sharing with the public.
How you choose to submit your Personal Data and How we collect your Personal Data:
We collect Personal Data about you in various ways as follows:
When you register with us directly;
When you join our mailing list to receive information, newsletters or other marketing communications from us;
When you pay for services, classes and evens or make purchases in our online store;
Through your relationship and communications with us, for example, if you contact us to ask a question about a class, or when you exchange emails with your teacher;
When you sign up to attend a class or event via a third party online reservation service (e.g. via Eventbrite);
When you contribute to online message boards or forums we provide (you will be identified when you post);
When you interact with us via Facebook, Twitter, Instagram or other online platform; or
When you visit our website (see 'Cookies' below). [link to Cookies]
How the Information is Used
We use your Personal Data for the following reasons and purposes (as further detailed below):
· for the performance of a contract with you or to take steps at your request before entering into a contract; (for example, when you register for a service, class or event, request materials from us, or when you purchase products or services);
· to comply with our legal and regulatory obligations;
· where we pursue our legitimate interests except where such interests are overridden by your own rights and interests; or
· where you have given consent.
Sensitive Information:
If we process sensitive data as referred to above (for example, if you post on the Site), including information about your philosophical or religious beliefs, we will only do this with your explicit consent where you have made public such information, and therefore the processing is carried out in the course of our legitimate activities or if otherwise permitted by applicable law.
We may use your Personal Data for one or more of the following purposes:
· Class and event administration: including responding to any queries you may have regarding classes or events you may be interested in, registering you as a student, confirming your class registration, providing you with all the information you need to attend events and to participate in classes you have enrolled in, recording your milestones, providing our events, classes and connected resources to you. We may contact you for the purposes of class and event administration using any of the contact details you provide to us, including text message.
· Fulfil an order for a product: processing your order and payment, keeping in touch regarding your order and delivering it to you.
· Identity checking: where necessary, conducting checks to identify our donors and verifying their identities.
· Operational reasons within our legitimate interests: such as improving efficiency, ensuring your teacher(s) have all the information they need to help you get the most out of classes (this may involve teachers sharing information about students when necessary), training and quality control, responding to queries you may have, ensuring that our internal policies are complied with, maintaining and updating our records, preventing unauthorised access and modifications to systems.
· To comply with legal or regulatory requirements: keeping all relevant tax records and for any other purpose required by law, regulation, the order of a court or regulatory authority.
· Marketing within our legitimate interests: providing you with direct marketing communications about what we are doing as well as products, services, classes and/or events which may be of interest to you by email, mail or phone. If required under applicable law, where we contact you by SMS, email, fax, social media and/or any other electronic communication channels for direct marketing purposes, this will be subject to you providing your express consent. You can object or withdraw your consent to receive direct marketing from us at any time, by contacting us using the following email: care@kabbalah.com.
· To enforce and/or defend any of our legal claims or rights.
The Personal Data that you provide during the purchase process on the Website is handled by a third-party e-commerce platform managed through Shopify for store purchases and NetSuite for Membership purchases.
Gift Recipient’s Personal Data:
In addition, when you submit data to us about other individuals (for example, when you purchase a gift), you thereby agree, represent and warrant to us in each instance that you have obtained consent from each such individual to the submission, transfer and processing of the information.
Sharing of Information
We may share or disclose non-personally identifiable information, whether aggregated or otherwise, with third parties.
Personal Information of Minors
The Centre does not knowingly solicit, nor does it knowingly collect, through the Site Personal Data from children under the age of sixteen. If the Centre learns that a child under the age of sixteen has submitted Personal Data online, the Centre will take reasonable measures to delete such information from its databases and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required by law).
However, a parent or legal guardian may register a child under the age of sixteen for a service, class or event. In such case, we will only use that child’s information for that event, or as other expressly agreed to by the parent or legal guardian.
External Distribution of Personally Identifiable Information and of Confidential Information
The Centre does not externally distribute Personal Data of a user, except if a user specifically opts-in to permit that certain of the user’s Personal Data be distributed to a third party, or if in connection with attribution for User Content contributed by a user through the Site, including by use of Facebook Connect or other social media links. External distribution does not include certain limited distributions such as sharing Personal Data with a third party working on behalf of the Centre, transfer of Personal Data in connection with the sale of the Centre’s assets or the merger of the Centre or the disclosure of Personal Data in connection with legal proceedings, investigations of crimes, or other governmental investigations. Transferring Personal Data in connection with a sale or merger and sharing Personal Data with an entity or person working on behalf of the Centre is considered an Onward Transfer. [link to below Onward Transfer section]
We may share your Personal Data with:
o Other Kabbalah Centre locations, who may assist us in providing you with newsletters, products and services, and provide us with operational assistance; and
o Third parties we use to help deliver our products and services to you e.g. payment service providers, online reservation service providers, delivery companies.
o We may also share Personal Data with external auditors, e.g. in relation to the audit of our accounts.
o We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
o In the event of a merger, reorganization or change of control of The Kabbalah Centre, Personal Data may be transferred to that reorganised entity or incoming controlling entity so that Kabbalah Centre can continue to operate.
Use of Your Information to Protect the Centre and Others:
We may release account and other Personal Data if we believe release is appropriate to comply with the law; enforce or apply our Terms of Use; or to protect the rights, property, or safety of the Centre, our other users, or third parties. This includes exchanging information with other companies and entities for fraud protection and credit risk reduction. We do not, however, sell, rent, share, or otherwise disclose Personal Data from users for commercial purposes without your consent.
Use of Cookies
The Centre uses “cookies”. “Cookies” is a text file that downloads small bits of information to your device. Cookies can note that a user’s browser was used to visit certain sites or pages on a certain date. The Centre uses cookies to enhance navigation and functionality of its Site. The Centre also uses cookies to enable the Centre to understand how visitors are using its Site, so that the Centre can modify its Site and enhance its offerings. Our website uses cookies to distinguish you from other users. This helps us provide you with a good experience when you browse and also allows us to improve our website.
Our website uses the following types of cookies:
o Necessary cookies: these cookies are essential for the website to function properly and cannot be disabled without severely affecting the usability of the website. The law does not require us to ask consent to use these cookies and they will always be placed when you use our website.
o Functional cookies: these cookies remember various choices you make on the website to improve your experience. They are also used to display recommendations for you based on your past activity on the website. Functional cookies may be required for actions such as watching a video.
o Any Personal Data that these cookies collect is anonymized before being used for any other purpose, so we don’t keep records of your data or track you personally, or monitor how you browse on other websites.
o We also use cookies from social media platforms like Facebook and Twitter to allow you to share information via your timeline or by liking or sharing content.
o Analytics cookies: these cookies gather anonymous data on how visitors use the website, for example, what pages are most visited and how long visitors stay on them. They also gather information on errors which may occur during visits which can help us fix them.
Managing cookies: most web browsers allow you to manage which cookies you accept via their settings. You can normally use the ‘Help’ functionality on your browser to find out about how it handles cookies and how you can manage your cookie preferences.
Onward Transfer
External distribution does not include certain limited distributions such as sharing Personal Data with a third party working on behalf of the Centre, the transfer of Personal Data in connection with the sale of the Centre’s assets or the merger or acquisition of the Centre or the disclosure of Personal Data in connection with legal proceedings, investigations of crimes, or other governmental investigations. Transferring Personal Data in connection with these limited distributions is considered an onward transfer to third parties and is permitted under this Privacy Policy.
Without limiting the foregoing, third parties may be engaged by us to perform a variety of services and functions, including providing technical and hosting services for our Site. These third parties may have access to your Personal Data if necessary to perform such services and functions; however, they are only authorized to use such personal information for the purpose of performing such services and functions, and are not authorized by us to use your Personal Data for any other purpose.
Additional Disclosures
You acknowledge and agree that the Centre may preserve or disclose any Personal Data if it reasonably believes disclosure is required by law or in the good faith belief that such preservation or disclosure is reasonably necessary to: (a) comply with legal process, including but not limited to civil and criminal subpoenas, court orders or other compulsory disclosures; (b) enforce this Privacy Policy and the Terms of Use of the Site; (c) respond to claims that any content violates the rights of third-parties; or (d) protect the rights, property or personal safety of the Centre, its members, employees, licensees or affiliates, other Site users and the public.
How Long We Keep Your Personally-Identifiable Information
We retain the Personal Data you provide to us as long as is reasonably necessary in connection with our business operations and your use of the Site, or for us to provide other services in connection with the Site.
We only retain Personal Data identifying you for as long as you have a relationship with us, or as necessary to perform our obligations to you (or to enforce or defend contract claims), or as is required by applicable law.
Personal Data we no longer need is securely disposed of and/or anonymized so you can no longer be identified from it.
Security
The Centre has implemented technology and security policies, rules, and other measures designed with the goal of protecting personal data that we have under our control from unauthorized access, improper use, alteration, unlawful or accidental destruction, and accidental loss. We also endeavor to protect your information by requiring that all our employees and others who have access to or are associated with the processing of your data to comply with this policy. In addition, we have reasonable security measures in place in our physical facilities intended to protect against the loss or misuse of information maintained at such facilities.
However, we cannot guaranty that third parties will never compromise our security measures.
Note also that we will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of our Site.
ALTHOUGH THE CENTRE USES REASONABLE SECURITY PRECAUTIONS WITH RESPECT TO YOUR PERSONAL DATA COLLECTED FROM AND STORED ON OUR SERVERS, THE CENTRE CANNOT GUARANTEE THAT ANY OF YOUR PERSONAL DATA STORED ON OUR SERVERS, OR TRANSMITTED TO OR FROM THE SITE, WILL BE FREE FROM UNAUTHORIZED ACCESS. TO THE FULLEST EXTENT NOT PROHIBITED BY LAW, THE CENTRE DISCLAIMS AND SHALL HAVE NO LIABILITY FOR ANY LOSS OF, UNAUTHORIZED ACCESS OR DAMAGE TO, OR INTERCEPTION OF ANY OF YOUR PERSONAL DATA BEING STORED ON OUR SERVERS OR ON THE SITE, OR TRANSMITTED TO OR FROM THE SITE IN CONNECTION WITH THE SITE SERVICES.
Use of Analytics Technology
We use Google Analytics to enhance navigation and functionality of the Site, and to let us know how users are using the Site, so that we can make Site improvements, where necessary. Google Analytics uses “cookies” (as described above) and “web beacons” which are typically images used to pass information from your computer to a website or server. The information about your usage of the Site collected through cookies and web beacons is transmitted to and stored on Google’s servers.
You may prevent Google Analytics from collecting information by installing the Google Analytics opt-out browser add-on. This add-on instructs the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) running on websites to prohibit sending information to Google Analytics. To opt-out of analytics for the Site, visit the Google Analytics opt-out page and install the add-on for your browser.
You may also opt out of the use of cookies (and web beacons when used in connection with cookies) by configuring your own browser settings directly to handle cookies. If you elect to opt out of cookies and web beacons, it may affect your ability to use the Site.
Links
The Site may provide links to web sites of third parties. The Centre is not responsible or liable for the privacy practices of these other web sites. ANY WEBSITES LINKED FROM OUR SITE ARE NOT SUBJECT TO THIS PRIVACY POLICY. YOU ARE RESPONSIBLE FOR REVIEWING THE PRIVACY POLICIES OF ANY LINKED WEBSITES TO DETERMINE HOW YOUR PERSONAL DATA WILL BE COLLECTED, UTILIZED, AND PROTECTED BY SUCH WEBSITES. WE ARE NOT RESPONSIBLE FOR ANY CONTENT, FEATURES, OR ACTIVITIES OF ANY LINKED WEBSITES (INCLUDING THEIR PRIVACY PRACTICES), AND THE CENTRE DISCLAIMS ANY AND ALL RESPONSIBILITY AND/OR LIABILITY FOR THE CONTENTS, FEATURES, AND ACTIVITIES, AND THE COLLECTION AND USE OF PERSONAL DATA BY SUCH WEBSITES.
The prices on our Site are subject to change at any time. Purchases for merchandise ordered from third party retailers are subject to the privacy policies and other terms of those third party retailers. Before you make a purchase of products from a third party retailer, you may be asked to establish an account or otherwise register with those third parties. Please review each third party’s Privacy Policy and Terms of Use before making a purchase or our product through those third parties.
Access; Review and Correction
Customers can, by emailing us at care@kabbalah.com to access, review and correct the Personal Data that has been collected from them by this Site.
Binding Agreement; Changes
This Privacy Policy and the Terms of Use of the Site constitute the entire agreement between you and the Centre regarding the use of the Site, the Site Content and the User Content. If any provision of this Privacy Policy and the Terms of Use is deemed invalid by a court of competent jurisdiction, the remaining provisions shall remain in full force and effect. The Centre’s failure to enforce any right or provision shall not be deemed a waiver of such right or provision. Headings are for convenience only and should not be given any interpretative effect.
Any user that accesses all or any part of this Site agrees that such user is at least sixteen (16) years old, or has accessed this Site with the consent of a parent or legal guardian and that such user has consented to this Privacy Policy. Each time a user accesses this Site, this Privacy Policy should be reviewed because the Centre reserves the right to change this Privacy Policy from time to time without prior notice. Your use of our Site constitutes your acceptance of the terms of this Privacy Policy.
The Site is operated by Kabbalah Centre International, Inc., 1062 S. Robertson Blvd., Los Angeles, CA 90035. All questions regarding the Site, this Privacy Policy or these Terms of Use shall be directed to our Data Privacy Officer by email at: DPO@kabbalah.com, by calling at: 1.800.KABBALAH, or by writing to our Legal Department at: Kabbalah Centre International, Inc., 1062 S. Robertson Blvd., Los Angeles, CA 90035.
Last updated May, 2018.
