Jennie Ma Academy

What Data We Collect and How We Use it

When you register and enroll as a subscriber (“learner”) and using our service and products, and browse our web pages (the “Site”), the “Company” collects Personal Information that can be used to identify you. The “Company” collects information about your interactions and transactions that may include, but is not limited to: e-mail addresses, and name (first and last).

The “Company” collects information about your interactions and transactions such as your device type, including mobile devices, the Internet Protocol (IP) address, browser type, browser version, the pages of our services that you visit., date and time, time spent on pages, and other device identifiers for diagnostic purposes.

The “Company” collects this information so that we may send e-mails about our “Site” and related courses, registration, course content, your course progress or other updates. We may also use your information to inform you about the changes to the course, evaluate you on the usage of the “Site”, or collect your opinion.

Cookies 

The “Company” uses cookies and similar tracking technologies to help track and measure the activity on our webpages, including mobile identifiers and help us recognize who you are, improve your experience, measure the effectiveness of and improve our products and services. When you use our “Site”, Cookies allow us to remember your personal choices and your personal and language preferences. Cookies help to provide you with a more personalized experience.

The “Company” may collect and store specific information to determine whether you have opened an e-mail or clicked on one of our links sent to you in an e-mail.

By using our “Site”, you consent to the placement of cookies and tracking beacons, tags, and scripts in your browser and HTML e-mails to collect and track information and in accordance with this “Policy”.

We also use cookies to attribute visits to our “Site” to third-party sources and to serve targeted ads from Google, Facebook, Instagram and other third-party vendors.

Our third-party advertisers use cookies to track your prior visits to our “Site” and elsewhere on the Internet in order to serve you targeted ads. For more information about targeted or behavioral advertising, please visit Network Advertising Initiative.

You can opt-out of targeted ads served via specific third-party vendors by visiting the Digital Advertising Alliance’s Opt-Out page.

You may be able to refuse all Cookies, but if you do not accept you may not be able to use some of our services.

Data Usage

The “Company” may use your Personal Information for the following purposes:

• Provide, maintain, and improve our products and services.
• Contact you and manage your requests and account.
• Conduct research.
• Provide you with information, special offers, and other goods and services which we offer similar to those that you have purchased, unless you have opted not to receive this information.
• Provide anonymous information about you to internal and external clients.
• We may share your information with service providers to monitor and analyze the use our service.
• We may share or transfer your Personal Information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business or another company.

Disclosure of your Personal Information and Your Rights

The “Company” does not share, rent, sell Personal Information with other individuals or companies except to provide the specific services and products that you requested.

We can share your information if we have your express permission by specifically asking you and under the following circumstances outlined below.

Business Transactions 

We may share your information with our business partners to offer you certain products services or promotions.

Marketing

The “Company” may send you information about our products and services that we think you might like for general processing purposes to deliver marketing, advertising, products, and services. We will delete your data upon request.

Law Enforcement

The “Company” will respond to disclosure of your Personal Information if required and permitted by law including, warrants, subpoenas, court orders, and other legal requests and processes, or to establish or exercise our legal rights or to defend and protect against legal claims. We may also disclose in the belief that this action is necessary to prevent or investigate possible violations in connection with the “Company” ‘Terms and Conditions[TK1] , or as otherwise required by law, or to protect the personal property and safety of users of the Service or the public.

Technical Support

In the event we or our third-party affiliates may need to provide you with technical support, we or our third-party affiliates may need to access the Personal Information you have provided to us. This “Policy” does not apply to access of this information or handling of it. The conditions regarding how this is handled, and the particular data are outlined in our ‘Terms[TK2]  and Conditions’ and any other agreements you have with the “Company”.

Please be aware that some interactions between you and the “Company” may involve the recording of interactions for training and quality control purposes. Such interactions may involve phone conversations, chat information, and other electronic communications. We will advise and obtain authorization before recording any conversations.

Storage and Security of Your Personal Information 

The security of your data is very important to the “Company” and we implement reasonable physical, administrative, and technical safeguards to help protect your information through the Thinkific Labs Inc. platform (“Thinkific’).

You are responsible for keeping your password secure. The “Company” is not liable for any loss or damage from your failure to maintain the security of your account and password.

If you provide us with your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with a AES-256 encryption. Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards.

No method of transmission over the Internet is 100% secure, however we strive to use reasonable commercial measures to secure your Personal Information from unauthorized access, use and disclosure. Your data is stored through Thinkific’s customer relationship manager application. Your data is stored on a secure server behind a firewall.

Payment and Financial Processing Data

If you make a purchase on the “Company” “Site”, we use a third-party payment processor such as Stripe or Paypal. Payments are encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction.

All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover.

PCI-DSS requirements help ensure the secure handling of credit card information by our “Site” and related courses and its service providers.

For more insight, you may also want to read Thinkific’s Terms of Service or Privacy Statement.

Data Retention

The “Company” retains your account information for as long as your account is active or needed to provide you with services. If you wish to request that we no longer use your information to contact you or provide you with services, please contact us using the information provided at the end of this “Policy”. We will retain your information as necessary to comply with our legal and regulatory obligations, resolve disputes, and enforce our agreements.

Data Analysis

The “Company” may use web-based analysis tools that are built into the “Company’s” “Site” to measure and collect anonymous session information.

Age of Consent

By using this “Site”, you represent that you are at least the age 18 or older or at least the age of the majority in your state or province of residence.

Third Party Services and Links

The “Company’s” third-party providers collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.

When you click on links on the course “Site”, it may contain linked to other websites that are not operated by us. If you click on a third-party link, you will be directed to the third party’s site. We advise that you review the policy of the site that you visit.

Certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us. If you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.

As an example, if you are located in   and your transaction is processed by a payment gateway located in the United States, then your Personal Information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.

We assume no control or responsibility for the content, privacy policies, or practices of any third part website or service.

Your Privacy Rights

In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your Personal Information. You may review, change, or terminate your account at any time.

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your Personal Information, (ii) to request rectification or erasure; (iii) to restrict the processing of your Personal Information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your Personal Information. To make such a request, please use the contact details provided below under contact us. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your Personal Information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

If you are resident in the European Economic Area and you believe we are unlawfully processing your Personal Information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here.

Account Information and Termination 

You may at any time review or change the information in your account or terminate your account by:

• Logging into your account settings and updating your account.
• Contacting us using the contact information provided here
• Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

Opting Out

Opting out of e-mail marketing: You can unsubscribe from our marketing e-mail list at any time by clicking on the unsubscribe link in the e-mails that we send or by contacting us using the details provided below. You will then be removed from the marketing e-mail list – however, we will still need to send you service-related e-mails that are necessary for the administration and use of your account.

You can also opt-out by:

• Noting your preferences at the time you register your account with the “Site”.
• Logging into your account settings and updating your preferences.
• Contacting us using the contact information provided below

Changes to the Freedom Frequency Privacy Policy

The “Company” may update our “Policy” from time to time. We may notify you of these changes by sending notification via the primary e-mail address specified in your account or by placing a notice on our “Site”.

You are advised to review this “Policy” periodically for any changes. Changes to this “Policy” are effective when they are posted to this page.

Contact Us

If you have any questions regarding this “Policy”, you may contact us at: [email protected]

If you are a resident in the European Economic Area, the “data controller” of your Personal Information is Jennie Ma. The “Company”, has appointed Jennie Ma to be its representative in the EEA. You can contact her directly regarding the processing of your information by the “Company”, by e-mail at [email protected] or by post to: 4 Lexington Avenue, New York, NY 10010, USA.

GDPR Compliance Statement

The “Company” is committed to ensuring the security and protection of the Personal Information that we process, and to provide a compliant and consistent approach to data protection.

We have created this GDPR Compliance Statement to explain our approach to implementing our GDPR compliance program. It describes the implementation of our data protection roles, policies, procedures, controls and measures to ensure ongoing compliance with GDPR.

Our GDPR Principles

The “Company” takes the privacy and security of individuals and their Personal Information very seriously. Our principles for processing Personal Information are:

• We will process all Personal Information fairly and lawfully
• We will only process Personal Information for specified and lawful purposes
• Where practical, we will keep Personal Information up to date
• We will not keep Personal Information for longer than is necessary
  

Data Subjects Rights under GDPR

At The “Company”, an individual can request information about:

• What Personal Information we hold about an individual.
• The categories of Personal Information we collect from an individual.
• The purposes for collecting and processing Personal Information from an individual.
• How long we plan to keep the Personal Information.

• The process to have incomplete or inaccurate Personal Information corrected or completed.
• About any automated decision-making that we use.
• Where applicable, the process for requesting erasure of the Personal Information or for restricting the processing of Personal Information in accordance with data protection laws, as well as to object to any direct marketing from us.

California Privacy Disclosure

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of Personal Information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared Personal Information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us with a proof of identity (valid driver’s license, U.S. passport) using the contact information provided under contact us.

We will make sure the data is not publicly displayed on the “Site”, but please be aware that the data may not be completely or comprehensively removed from our systems.

California Consumer Protection Act (CCPA)

CCPA California consumers are permitted to have access and control regarding collection, use and sharing of information under the California Consumer Privacy Act (CCPA). California consumers may also “opt out” of the sale of Personal Information to third parties, as defined under CCPA.

The “Company’s” Privacy Policy describes the way we collect your Personal Information, the source of the information, purpose of collecting your information and the circumstances where your information may be shared with third parties outside of the “Company”.

California consumers who have the “Company” account may exercise their rights to access  categories of Personal Information about you, and to request or delete parts of or all of your personal data. Requests may be made by contacting us. 

Categories of Personal Information

This section describes which categories of information the “Company” collects and how we process that information.

We collect Personal Information of our clients, potential clients, and website users. If the information that we collect is not listed on this “Policy”, we will provide individuals (when required by law) notice of which other information is collected and how it is used.

Below is a table of the categories of Personal Information the “Company” collects, and processes as described in our “Policy”.

Any Personal Information that the “Company” holds may also be used to comply with applicable law.