(Effective Date: April 2, 2020)

This White Tiger Kung Fu Privacy & Cookies Policy (this “Privacy Policy”) explains how your personal information is collected, used and disclosed by White Tiger Kung Fu, Inc. and the White Tiger Kung Fu affiliates listed in the “Data Controllers and Contacting Us” section below (“White Tiger Kung Fu”, “us”, or “we”) and how we collect information through the use of cookies and related technologies. It also tells you how you can access and update your personal information and describes the data protection rights that may be available under your country’s or state’s laws, including (in the European Economic Area (“EEA”)) a right to object to some processing that we carry out or, where we rely on consent, how to withdraw that consent.

This Privacy Policy applies to personal information we obtain from or about you when you (i) visit all internet sites operated by White Tiger Kung Fu that link to this Privacy Policy (collectively, the “Sites“); (ii) interact with our social media pages and advertisements, customer services, webinars or blogs; or (iii) participate in our events and demonstrations. White Tiger Kung Fu acts as the data controller for the data processing operations described in this Privacy Policy.

We may provide additional information about our privacy practices at other points, for example, when we ask you to provide personal information in connection with a particular service, and where this will help us provide more relevant and timely information.

We reserve the right to make changes to our practices and this Privacy Policy at any time. If we change the way we handle your personal information, we will update this Privacy Policy and notify you as appropriate.

This Privacy Policy addresses the following:

1. Information that we collect about you
2. Cookies and other tracking technology that we use
3. Uses made of your personal information and our legal basis for processing
4. Disclosures of your personal information
5. Withdrawing consent or otherwise objecting to White Tiger Kung Fu’s direct marketing
6. EEA data protection rights
7. California privacy notice
8. Miscellaneous

1. INFORMATION THAT WE COLLECT ABOUT YOU

Customers and Website Users

Information Provided by You Upon Registration and/or Making a Purchase. When you register for an account on a Site and/or purchase a product or service from us, we collect information that allows us to identify you, such as:

• Name
• E-mail address
• Address (where entered as part of a “business/location scan”)
• ZIP/Postal Code
• Home Phone
• Mobile Phone
• Credit Card Number
• Billing Address
• White Tiger Kung Fu login details (username and password)

Information Provided When You Contact Us. We also collect personal information that you voluntarily provide to us when you contact us with a question or comment about our products and services, download our whitepapers or sign up for product demonstrations or events.  Typically, this includes:

• Name
• E-mail address
• Phone Number
• Information about your interests and preferences
• Content of the communication

Passively Collected Information. When you access our Sites, we automatically collect (i) technical information about your device including your device’s internet protocol (IP) address, your browser type and version, time zone setting, and operating system and platform; and (ii) information about your visit, including the URL clickstream to, through and from our Sites (including date and time), products you viewed or searched for, your account activity (when logged in), the content (and any ads) that you view or interact with, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page. Some of this information is collected using cookies and related technologies. See Section 2 for more detail.

Information Collected From Our Partners. We may partner with our third party resellers to receive information about you, such as name and contact information.  This helps us to fulfill your service requests and/or to provide you with services that may be of interest to you.

Partners, Publishers and other Service Providers

We will process certain contact information about individuals within organizations that we work with such as publishers, mailing houses, payment providers, IT hosting and maintenance providers, events companies and other service providers.

2. COOKIES AND OTHER TRACKING TECHNOLOGIES THAT WE USE

We and our service providers use cookies, beacons, embedded scripts and local shared objects in connection with the Sites.

• Cookies are small text files that are stored on your computer when you visit our websites. Cookies allow a website to recognize a particular device or browser. The use of cookies is a standard practice among websites to collect information about visitors’ activities while using the website. To the best of our knowledge, we do not deliberately use cookies except for standard cookies created by Google Analytics and wordpress.org.
• Beacons are small graphical images (also known as “pixel tags” or “clear GIFs”) that may be included on our Sites and in email communications and typically work in conjunction with cookies to identify our users, their devices and behavior, type of email applications used, screen resolution in order to check if our communications have been opened and acted upon, and to provide content and ads that are more relevant to you.
• An embedded script is a programming code that is designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your device from our web server or a third-party service provider, is active only while you are connected to the Site, and is deactivated or deleted thereafter.

The above technologies are used in analyzing trends, administering the Sites, services and products, tracking users’ movements around the Sites and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

The table below sets out the cookies we use on the Sites, their purpose, and how you may opt out of our use of these cookies.

You can also change your cookie settings via your browser. For further information, visit www.allaboutcookies.org.

The length of time a cookie will stay on your browsing device depends on whether it is a “persistent” or “session” cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your browsing device after you have finished browsing until they expire or are deleted.

3. USES MADE OF YOUR PERSONAL INFORMATION AND OUR LEGAL BASIS FOR PROCESSING

Providing personal information is optional; however, in order to provide you with access to our services and other resources such online training courses, providing certain personal information (e.g., contact information and name, log-in details) may be necessary in order to receive these services and resources. You may choose whether or not to receive electronic marketing communications from us and we will only send you such communications where we have the appropriate consents to do so (to the extent required by applicable law). For more information on your choices, please see Section 5 below.

We process personal information through electronic and manual means for the following purposes:

Customers and Website Users

As required to conduct our business and pursue our legitimate interests, in particular:

• to improve and personalize your experience with us and our Sites and to tailor content, advertisements and offers to you;
• to administer our Sites, conduct identity verification and other fraud detection activities;
• to send you information you have requested;
• to monitor, maintain and improve the performance of our Sites, analyze trends, usage and activities in connection with our services, validate users and ensure their technological compatibility with users, and optimize our marketing efforts and measure the effectiveness of our advertising campaigns;
• for our own internal functions such as keeping our Sites secure, management and corporate reporting, internal research and analytics and to improve business efficacies;
• to enforce compliance with our terms of use and other policies or otherwise in connection with legal claims, compliance, regulatory and investigatory purposes as necessary (including disclosure of such information in connection with legal process or litigation);
• to create aggregate and statistical data (which cannot be used to identify you). For example, aggregate data may include data that describes the general demographics, usage or other characteristics of a Site’s users. We reserve the right to transfer and/or sell aggregate or group data about a Site’s users for lawful purposes.

Where you give us consent:

• Where you ask us to send marketing information via a medium where we need your consent under applicable law (for example email marketing in some countries). For more information about how to modify your preferences about marketing communications, please see Section 5;
• Where you give us consent to place cookies or similar technologies;
• On other occasions where we ask for your consent, for the purpose we explain at the time.

As required by law:

• In response to requests by government or law enforcement authorities conducting an investigation.

Partners, Publishers and other Service Providers

We use contact information about individuals within other organizations that we work with in order to fulfill our contractual obligations or as required to conduct our business and pursue our legitimate interests including for our own internal functions such management, corporate reporting, and record keeping.

4. DISCLOSURES OF YOUR PERSONAL INFORMATION

We will share your personal information with the third-parties listed below for the purposes that are described in this Privacy Policy or otherwise with your consent.

Service Providers. When we employ an affiliate or third-party to perform a function on our behalf, we provide it with the personal information that it needs to perform its specific function. These companies are authorized to use your personal information only as necessary to provide these services to us. We use service providers for the purposes of delivering our products and services, managing your accounts, hosting, IT, security, support, billing, marketing, and communications.

Affiliates. White Tiger Kung Fu is a global business, headquartered in the United States. Your personal information collected by us in accordance with this Privacy Policy may be used and shared amongst White Tiger Kung Fu, Inc. and the White Tiger Kung Fu affiliates for the purposes of delivering our products and services, managing your accounts, hosting, IT, security, support, billing, marketing, and communications. The list in Section 7 describes the management responsibility for respective data processing activities by the listed White Tiger Kung Fu affiliates. If your personal information is transferred from Japan (and subject to Japanese privacy laws), it will be considered to be jointly used between White Tiger Kung Fu, Inc. and the listed White Tiger Kung Fu affiliates in accordance with the joint use cases set forth in Section 7.

Legal Requirements. We disclose personal information to government authorities or other third-parties if required to do so by law or in the good faith belief that such action is necessary to (a) comply with a subpoena, court order or similar legal obligation, (b) protect and defend our rights or property, (c) act in urgent circumstances to protect the personal safety of users of any Site or the public, (d) protect against legal liability, (e) to investigate fraud or other unlawful activity or (f) or as otherwise required or permitted by law.

Business Transfers. As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, including in bankruptcy, your personal information may be part of the transferred assets. You will be notified via email and/or a prominent notice on our Sites of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Third-Party Partners.  We may share your personal information with selected third-party partners, including for their direct marketing purposes. We will obtain your prior consent for such a transfer where required by applicable law.

International Transfers of Personal Information. Your personal information is stored on servers in the US and is supported from the US. Our primary email service provider is Mailchimp, Accounting Software is Quickbooks, and payment processor is Heartland payment systems.  We also store Personal Information on our hardware and software at our the physical locations of our schools. To the best of our knowledge, we do not send any personal information outside the U.S. and/or on these service provider’s systems.

5. WITHDRAWING CONSENT OR OTHERWISE OBJECTING TO WHITE TIGER KUNG FU’S DIRECT MARKETING

Where we rely on consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above in Section 3. You have the absolute right to opt out of our direct marketing at any time, and EEA individuals can also opt out of profiling we carry out for direct marketing at any time. To stop receiving newsletters or marketing communications from us, you can use the unsubscribe mechanism in the relevant communication or you can send an email to [email protected] with information necessary to process your request. Please note that this will not stop you from receiving service related messages (i.e., non-marketing communications) such as email messages to let you know our service has been suspended for maintenance.

6. EEA DATA PROTECTION RIGHTS

If you are an individual located in the EEA, you have the right to ask us for a copy of your personal data, to correct, delete or restrict processing of your personal data, to obtain the personal data you provide to us in a structured, machine readable format, and to ask us to share (port) this data to another controller. In addition, you can object to the processing of your personal data in some circumstances (in particular, where we are not required to process such data in order to meet a contractual or other legal requirement).

If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.

If you deactivate your account, we will delete, block or anonymize your personal information so that it is no longer possible to identify you, subject to our retention policy below.

If you have provided a location review to one of our customers, please contact that customer directly if you have any questions about their privacy practices or wish to stop receiving communications from or exercise your rights in respect of personal data processed by that customer.

7. CALIFORNIA PRIVACY NOTICE

If you are a California resident, this section contains disclosures required by the California Consumer Privacy Act (“CCPA”) and applies only to “personal information” that is subject to the CCPA.  This section does not cover personal information about End Users of our customers, which we process solely on behalf of customers.

Currently, personal information about our current and former business customers is exempt from most CCPA obligations.  We do not and will not sell personal information about our business customers, former customers, or business (marketing) prospects.

We provide our business prospects with additional disclosures and rights under the CCPA. The remainder of this section provides additional information for our business prospects.

Accessibility.  Consumers with disabilities may access this notice by using a standard screen reader.

California Personal Information We Collect and Disclose.  We collect the categories of personal information listed in the below chart about California residents who are our business prospects.  As further set forth in the chart below, in the past 12 months, we have disclosed such California residents’ personal information to third parties for the listed business or commercial purposes.  We do not and will not sell such personal information.