Privileged and Confidential Last Revised December 15, 2021
Effective Date: December 15, 2021
Assemble, owned and operated by Magnolia Media Corporation,
1. Types of Information We Collect 2. How We Collect Information 3. How We Use Information 4. Legal Basis for Use of Your Information 5. Disclosures of Information 6. Online Tracking Technologies 7. Protecting Your Personal Information 8. Personal Information of Minors 9. Your Choices 10. Data Rights 11. Do Not Track 12. Retention 13. International Data Transfer 14. Contact Information
We collect several types of information from and about users of our Website, including the following personal information:
We may collect information: Directly from you. We may collect information that you provide to us online, such as when you create an account, rent a course, or participate in contests or surveys. From your device. We may use certain tracking technologies to collect information about your use of the Website[, or our app]. These tracking technologies include cookies, pixel tags, web beacons, scripts, and other similar technologies. From social media partners. We may also receive information about you from your use of social media features within our Website[ or our app]. From other third parties. We may receive information about you, including your use of the Website[ or our app] from other third parties who provide services on our behalf, including payment processors like Stripe and data services providers like Google. We recommend that you review these third parties’ privacy notices to learn more about their practices. To learn more about our use of Google Analytics, more information may be found here.
Assemble may use your information for the purposes described below. In addition to this section, we also provide the legal bases for which we use your information in Section 4.
3.1. Provide you with products and services. We may use your information to provide you with products and services that you purchase from us and to provide you with customer support. 3.2. Communicate with you. We may use your information to contact you about products and services that you have purchased or answer any inquiries you may have about Assemble, including our services. 3.3. Improve our products and services. Assemble may use your information to operate, maintain, and improve our Website[ and our app], including analyzing your use and evaluating performance of the same. We may also use your information to customize or personalize your experience with us. 3.4. Market products and services. We may send you information about promotions, offers, and new content. 3.5. Maintain security and protect rights. We may use your information to protect our rights and those of our users and others and to ensure the security of the same. 3.6. Comply with or as otherwise permitted by applicable law. We may use your information to comply with relevant federal, state, and local law enforcement authorities. We may also use your information to resolve disputes, enforce our agreements, or as otherwise permitted by law. 3.7. Mergers and acquisitions. We may share your information as part of a merger, acquisition, or other sale or transfer of all or part of our assets or business. 3.8. Third party processing. We might be required to collect and transfer your information to our financial institution or payment service provider to allow your financial institution and the payment service provider to comply with their legal obligations, such as obligations under applicable anti-money laundering and counter-terrorism financing legislation.
We may use your information for other purposes provided we obtain your consent, or where the information is aggregated or de-identified such that it cannot reasonably be linked to you. 4. Legal Basis for Use of Your Information The legal bases for using your information as described in this Privacy Notice are as follows: • We process your information to provide you the products and services you requested as set out in Section 3.1, as far as this is necessary for performing the agreement between you and Assemble. • You can opt-in for the communications referred to in Sections 3.2 and 3.4. By opting-in you give us your consent for this processing activity. • The processing of your information for the purposes outlined in Sections 3.3 and 3.5 is necessary for the purposes of the legitimate interests of Assemble, which are: ◦ Continuous improvements of our website, products and services to ensure that you have the best experience possible; ◦ Keeping our website safe from misuse and illegal activity; ◦ Marketing and promotion of our products, services, and overall successful commercialization of our products and services. • The processing of your information for the purposes outlined in Sections 3.6, 3.7 and 3.8 is necessary to allow us to comply with our legal obligations.
Assemble may share information with: • Service providers. We may share information with third parties who perform services on our behalf. These third parties may provide a variety of services, including payment processing, data and website analytics, emailing services, and fraud prevention. • Third parties to comply with applicable law. We may share your information with law enforcement, regulators, and courts to comply with court orders, law or legal processes, such as responding to government or regulatory requests. • Third parties to protect ourselves and others. Assemble may also share your information with third parties if we believe it is necessary to protect you, our users, others, or ourselves. This may include investigating suspected or actual fraudulent or illegal activity. • Successors to all or part of our business. We may share your information in the event that we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation). For instance, we may provide our customer list as part of a transaction. We may share information about you for other purposes with your consent, or where the information is aggregated or de-identified such that the information cannot reasonably be linked to you.
Assemble and our service providers use cookies and similar technologies, such as cookies, Flash web beacons and other tracking technologies (collectively, “Tracking Technologies”) to collect information described in Section 1 (Types of Information We Collect). The information that we collect is used for the purposes described below: • Sign-In. We use Tracking Technologies to store your sign-in information so that you do not have to sign in to Assemble each time you visit a page. • Fraud protection. Tracking Technologies help us detect fraud and illegal use of the Website, including attempts to access the Website without authorization. • Analytics. Tracking Technologies help us gather data on Website usage and performance, such as counting the number of users who visited a page. • Advertisements. We use Tracking Technologies to collect information on your interests so we can tailor ads to you. We also use such technologies to track how many users have clicked on an advertisement to help us measure an ads effectiveness and limit the amount of times you are shown a particular ad. • Customize your experience. We use Tracking Technologies to learn how you use our Website so that we can tailor your experience to your interests. We work with third parties, such as Google (e.g., through Google Analytics), to better achieve the purposes described above. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website. Certain features of our website may use local stored objects or Flash cookies to collect and store information about your preferences and navigation to, from, and on our website. Flash cookies are not managed by the same browser settings that are used for browser cookies. Pages of our website may contain small electronic files known as web beacons, also referred to as clear gifs, pixel tags, and single-pixel gifs, that permit us to count users who have visited those pages, and allow us to see other related website statistics, for example, recording the popularity of certain website content and verifying system and server integrity. [Our app uses Software Development Kits (“SDKs”) which are pieces of computer code used by mobile app developers to enable various features of mobile apps. For instance, SDKs may be used to provide advertising services or enable data to be collected for analytics purposes.]
We implement reasonable security practices designed to protect your personal information in our possession or control from unauthorized access, use, alteration, and disclosure. However, no personal information sent across the Internet can be fully secure or free from error. We encourage you to monitor your personal information and be vigilant about protecting it.
Our Website [and app] is intended for adults. We do not knowingly collect the personal information of users under 18 years of age.
If we engage in email marketing, we will provide you the option to opt in to receiving such communications. If you no longer wish to subscribe to Assemble’s mailing list, you may click the “unsubscribe” link in an email at any time. You may see certain ads on other websites because we participate in advertising networks. These advertising networks track your online activities by collecting information through automated means, such as through the use of cookies, web server logs and web beacons. The advertising networks use this information to show you advertisements that may be specific to your interests. The information our advertising networks may collect includes information about your visits to websites that participate in the relevant advertising networks, such as the pages or advertisements you view and the actions you take on the websites. This process also helps us track whether our marketing efforts are effective. To learn how to opt out of this ad network interest-based advertising, click here.
You may have data rights depending on the state of your residency. You may exercise any rights that you have to access or delete your personal information or opt out of the sale of personal information as defined by law, by using the method described in this section. We will process your request as and to the extent required by law.
You may also have rights if you reside outside of the United States. These rights may include the right to object to processing, which is the right to object to particular uses of your personal information. Additional rights may include:
• Right of access: your right to request access to all information processed by us pertaining to you. We reserve the right to charge an administrative fee for multiple subsequent requests for access that are clearly submitted for causing nuisance or harm to us.
• Right to portability: your right to request that Assemble provide you (or a third party you designate) with your personal information in a structured, commonly used and machine-readable format. You may have the right to transmit those data to another business.
• Right to correction: your right to ask that any information pertaining to you that is inaccurate, is corrected free of charge. Your request for correction must be accompanied with proof of the flawed nature of the data for which you ask the correction.
• Right to erasure: your right to request that information pertaining to you will be deleted if it is no longer required in light of the purposes outlined in this Privacy Notice or if you withdraw your consent.
• Right to restrict processing: your right to request that Assemble restrict any processing of your personal information.
• Right to withdraw consent: where processing of your information is based on your consent, you may withdraw this consent at any time. Note that withdrawal of consent may imply that you can no longer use the whole or part of our services.
• Right against automated processing: your right to request not to be subject to a decision solely based on automated processing, which produces legal effects concerning you or when this decision similarly significantly affects you, unless these decisions are made as a consequence of our agreement in order to provide you with the services requested by you or when we asked your explicit consent for this.
We will consider all requests and provide our response within the period required by applicable law. Certain information may be exempt from such requests in some circumstances, such as when we need to keep processing your information to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request.
To exercise your rights, please contact Support@Assemble.fyi The request should clearly state which right you wish to exercise and, if required, the reasons or proof for it.
If you wish to raise an issue in connection with our use of your personal information, we encourage you to get in contact with us in the first instance. In the EU, you have the right to lodge a complaint about our processing of personal information with a supervisory authority, in particular in the EU Member State where you live, work, or where the alleged infringement took place. In the UK, the supervisory authority is the UK ICO (https://ico.org.uk/).
Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not uniform across browsers. We do not currently respond to do not track signals. Please be aware that if you block or reject cookies, not all of the tracking described here will stop.
We will retain your personal information as long as reasonably necessary to fulfill the purposes for which we collected it (as described above). We may also retain your information to meet legal obligations, resolve disputes, maintain security, prevent fraudulent and illegal activity, enforce our agreements with you, or fulfill your rights requests. In some instances, we may anonymize your information such that it can no longer be associated with you for internal business purposes, such as improving and maintain our services. In this case, we may use this information indefinitely without further notice. Further information about our retention periods is available on request, by contacting us using the contact details set out below.
Assemble is located within the United States. When you engage with our Website [or our app], you may be sending personal information into the United States. When we transfer your personal information onwards to third parties outside the EEA or UK, we will ensure appropriate safeguards are in place to protect the personal information. You can request further information about how we legitimize transfers of personal information outside the EEA or UK by contacting us using the contact details set out below. We safeguard your information by processing it in accordance with this Privacy Notice. We use reasonable secure methods to collect personal information through our Website [and our app]. We also enter into contracts with our service providers that require them to treat personal information consistent with this Privacy Notice.
To ask questions about or comment on this Privacy Notice or our privacy practices, you may contact us at Support@Assemble.fyi
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