PrivacyPolicy
About this Policy
This Privacy Policy (“Privacy Policy”) details our data collection processes, including the data we receive about you and how we process it, and your rights and obligations in relation to your personal data.
Unless we link to a different policy or state otherwise, this Privacy Policy applies when you visit or use the Gropino services such as any Gropino website (the “Site”), community and customer service links or chat functionality, mobile applications, social media pages or handles, online and offline products and events, APIs or related services, and any accompanying services you are eligible to receive, such as teacher support services and tools (together, the “Services”). It also applies to prospective customers and enterprise products. By using or accessing the Services, you agree to the terms of this Privacy Policy. From time to time, we may develop new or offer additional services. They'll also be subject to this Privacy Policy, unless stated otherwise when we introduce them.
Capitalized terms not defined here have the meanings set forth in the Terms of Service (the “Terms”), located at www.gropino.com. Your use of the Sites and Services is also subject to the Terms. You shouldn’t use the Services if you don’t agree with this Privacy Policy or any other agreement that governs your use of the Services, including the Governing Documents.
Personal Data We Collect About You
When you register with us, when you become a Gropino Member, when you choose to teach or attend a class, or when you engage with Gropino-sponsored webpages, including those involving surveys or quizzes, we may ask you for Personal Data. “Personal Data” refers to information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. In addition, we may collect data that is not identifiable to you or otherwise associated with you, such as aggregated data. This is not Personal Data. To the extent this data is stored or associated with Personal Data, it will be treated as Personal Data; otherwise, the data is not subject to this Privacy Policy.
These tables set out the categories of personal data we collect and use.
Information you provide to us when you sign up for the Services, update your account, or use the Services
User Data & Identifiers
Personal data that we need to create your account and that enables you to use the Services.
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 name, alias, email address, postal or billing address, zip code, account name, phone number, social media profiles, or other similar identifiers.
Payment Information
If you sign up for a membership, free trial, or other service, or make purchases, we collect certain data about your purchase (such as your name, billing address, and others) as necessary to process your order and which may be saved to process future orders. The exact personal data collected and used will vary depending on the payment method.
You must provide certain payment and billing data directly to our payment service providers, including your name, credit card information, billing address, and ZIP code. We may also receive limited information, like the fact that you have a new credit card and the last four digits of that card, from payment service providers to facilitate payments. Gropino does not collect or store sensitive cardholder data, such as full credit card numbers or card authentication data.
Teacher Payment Information
If you are a Gropino Teacher, you can provide your Paypal or other payment account to the Services to receive payments through our third party service providers. When you link a payment account, we collect and use certain information, including your payment account email address, account ID, physical address, or other data necessary for us to send payments to your account. In some instances, we may collect ACH or wire information to send payments to your account. In order to comply with applicable laws, we also work with trusted third parties who collect tax information as legally required. This tax information may include residency information, tax identification numbers, biographical information, and other personal information necessary for taxation purposes.
Other Information
Additional data you may choose to give us includes:
demographic information such as your gender or other information;
user-generated content you provide to us, such as when you upload a project, upload courses and other educational content, leave a class review, ask or answer a question, or otherwise participate in a public discussion forum;
information you provide when you participate in a survey or research study, including testimonials;
participation in promotions, sweepstakes or contests, or other marketing promotions;
Information you provide when you communicate with our customer support team; and
Information about others, including email address, for referral invitations.
Information automatically collected through your use of the Services
Category Description
Usage Data
When you use our Services, we collect and analyze:
technical data such as your IP address, browser types, browser language, operating system, software and hardware attributes (including device IDs), online identifiers such as cookie data, referring and exit pages, and URLs;
Gropino app data such as 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, error logs, and other similar information about how you use the app;
site usage patterns such as the number of clicks, mouse movements, scrolling, and time spent on a page;
navigation data such as pages viewed and the order of those pages, date and time of use, session duration, and error logs;
learning data such as content or classes watched, total minutes watched, and categories of classes you search for; and
other similar information.
We may use third-party providers such as Crazy Egg to log your activity. This provides us with a set of data and a session replay of your activity on Gropino in the form of a video. Third-party providers like Crazy Egg capture and analyze your usage data to help us make your Gropino experience better.
General (Non-Precise) Location
Your general location includes country, region, or state. We may learn this from technical data (e.g. your IP address, language setting of your device) or payment currency.
Information collected from partners and other third parties
Category Description
Third Party Services
If you link, connect, or login to the Services with a third party service (e.g. Google, Facebook, Apple), you direct the service to send us information such as your registration and profile information as controlled by that service or as authorized by you via your privacy settings at that service.
Payment Partners and Merchants
If you choose to pay through third parties or by invoice, we may get data from our payment partners. This allows us to send you invoices or process your payments.
If we direct you to a merchant, we receive data from the merchant that is related to your purchase. For example, we might direct you to one of our partner’s websites on a third party platform. Receiving this data allows us to analyze the effectiveness of our partnership with these merchant partners and understand your interests.
Information from Other Sources
We also obtain information from other sources. We protect this information according to the practices described in this Privacy Policy, plus any additional restrictions imposed by the source of the data.
These sources vary over time, but could include:
service providers that help us determine a location based on your IP address in order to customize our service and for other uses consistent with this Privacy Policy;
security service providers who provide us with information to secure our systems, prevent fraud, and help us protect the security of Gropino accounts;
payment service providers who provide us with payment or balance information, or updates to that information, based on their relationship with you;
online and offline data providers, from which we obtain aggregated demographic, interest-based, and online advertising related data;
publicly-available sources such as publicly available posts on social media platforms and information available through public databases associating IP addresses with internet service providers; and
advertising or marketing partners from whom we receive inferences (i.e., their understanding) of your interests and preferences.
We may also receive additional information such as demographic and statistical information from third parties, including 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, provide more relevant experiences for you, and improve our products, analytics, and advertising.
How We Use the Personal Data We Collect About You
We may use the information we collect about you for various purposes, including to provide, analyze, administer, enhance, and personalize the Services and marketing efforts; to process your subscription, purchase, or payments; to communicate with you on these and other topics; to evaluate and improve the Services; and to comply with legal obligations. For example, we use such information to:
create and manage your accounts and profiles;
personalize your content on the Services–this includes providing you access to your saved classes and class watch history, and providing class recommendations;
provide users and Teachers with features and functionality, including to facilitate participation in our content, classes, lessons, courses, and live events, and that of our Teachers; issue completion certificates, badges, or other credentials; or to facilitate social or community features, such as by identifying and suggesting connections with other users or Teachers of the Service and providing discussion boards, chat, or messaging functionality;
provide Teachers with information related to student engagement and minutes watched, referral earnings, and other analytical data, including data that is used to pay Teachers appropriately;
manage student and Teacher referrals;
secure our systems, prevent fraud, and help us protect the security of Gropino accounts;
prevent, detect, and investigate potentially prohibited or illegal activities, including fraud, and to enforce our Terms of Service or our Community Guidelines;
analyze and understand our audience (including to understand demographic patterns related to our community), improve our Service (including our user interface experiences and service performance), and optimize content selection, algorithms, and delivery;
communicate with you concerning the Services so that we can send you news about Gropino or our third-party partners, details about new features and content available on Gropino, special offers, promotional announcements, consumer surveys, and to assist you with operational requests such as password reset requests;
fulfill contractual obligations with third parties;
complete corporate transactions (for more information, see our “Business Transfers” section below); and
fulfill any other purpose at your direction.
Disclosing Your Personal Data
Affiliates and Subsidiaries
To support us in providing, integrating, promoting, and improving the Services, we may share personal information within our corporate family of companies that are related by common ownership or control.
With Your Consent or at Your Direction
Where you provide consent, we share your information as described at the time of consent, such as when authorizing a third-party application or website to access your Gropino account or participating in promotional activities by Gropino partners or third parties.
Educational Experience
To facilitate interactions between our Teachers and users, we share with Teachers data that we have about users concerning content users access or request information about, so Teachers can improve their content for you and other students. This data may include things like your name, email address, country, browser language, operating system, device settings, the site that brought you to Gropino, and certain activities on Gropino, like how many minutes you have watched and for what class or other content.
Depending on your settings, your shared content and profile data may be publicly viewable, including to other students and Teachers. If you leave a review, ask a question, or post on a discussion board, your information (including your name) may also be publicly viewable. Note that within the Services, all discussion boards, groups, or other public forums available to participants are publicly visible to other participants. Accordingly, please take care when using these forums and do not post confidential or proprietary information through those features.
Service Providers
We share Personal Data with vendors, service providers, and agents who work on our behalf and provide us with services related to the purposes described in this Privacy Policy or our Terms of Service. These parties include:
Payment processors
Fraud prevention service providers
Providers of advertising services
Video content providers
Ad networks and marketing tools
Analytics service providers
Engineering and development tools
Staff augmentation and contract personnel
Hosting service providers
Teachers
Other Third Parties
We also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include:
other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Services), such as when users and Teachers interact through the Services;
social media services (if you interact with them through your use of the Services);
business partners that you access through the Services or that we engage to offer co-branded services, sell or distribute our products, or engage in joint marketing activities.
Promotional Offers
We may offer joint promotions or programs that, in order for your participation, will require us to share your information with third parties. In fulfilling these types of promotions, we may share your name and other information in connection with fulfilling the incentive. Please note that these third parties are responsible for their own privacy practices.
Aggregate/Anonymous Data
From time to time, we may share aggregated or anonymous information about use of the Services, such as by publishing a report on usage trends.
Protection of Gropino and others
We also share Personal Data when we believe it is necessary to:
Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies;
Protect us, our business, our users, and others, for example to enforce our terms of service, prevent spam or other unwanted communications, and investigate or protect against fraud;
Maintain the security of our products and services.
Business Transfers
In connection with any reorganization, restructuring, merger or sale, or other transfer of assets, we will transfer information, including personal information, provided that the receiving party agrees to respect your personal information in a manner that is consistent with our Privacy Policy.
Legal Bases for Use of Your Information
We process Personal Data for, or based on, one or more of the following legal bases:
Performance of a Contract
By using the Services, you have contracted with us through the Terms of Service, and we will process certain Personal Data to perform under that contract, including first and last name, email address, password, and, if you are a Teacher, the content of your classes. When we process Personal Data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.
Legitimate Interests
We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties: first and last name, email address, location information, IP address, and your activity on the Services, including class usage information and community interaction data. Examples of these legitimate interests include: operation and improvement of our business, products, and services; personalization of web content on the Services; analyzing the use of the Services; marketing of our products and Services; provision of customer support; protection from fraud or security threats; compliance with legal obligations; and completion of corporate transactions.
Consent
In some cases, we process Personal Data based on the consent you expressly grant to us prior to the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you prior to the point and time of collection.
Other Processing Grounds
From time to time, we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
Retention of Your Information
We will retain your Personal Data for as long as your account is active or as needed to provide you services and to maintain a record of your transactions for financial reporting purposes. We will also retain and use your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Protection of Your Information
Gropino takes technical and organizational security measures that are designed to safeguard Personal Data. However, no online activity is ever fully secure or error-free. While we strive to protect your information, we cannot guarantee that your Personal Data is absolutely secure. Please keep this in mind when disclosing any information to Gropino.
Please recognize that protecting your Personal Data is also your responsibility. We urge you to take every precaution to protect your information when you are on the Internet, or when you communicate with us and with others through the Internet. Change your passwords often, use a combination of letters and numbers, and make sure you use a secure browser. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account might have been compromised), or if you suspect someone else is using your account, please let us know immediately by contacting us as indicated in the Contact Us section below.
Transfer to Other Countries
Because of the global nature of our business, Gropino shares personal data internationally with its subsidiaries, subcontractors, and partners when carrying out the activities described in this Policy. They may process your data in countries whose data protection laws are not considered to be as strong as EU laws or the laws which apply where you live. For example, they may not give you the same rights over your data.
Whenever we transfer personal data internationally, we use tools and transfer agreements to:
make sure the data transfer complies with applicable law; and
help to give your data the same level of protection as it has in the EU and the laws which apply where you live.
Regardless of where you use our Services, the information collected as part of that use will be transferred to and maintained on servers located in the United States. By using our Services, you consent to this collection, transfer, storage, and processing of information to and in the United States.
Use of Cookies and Other Tracking Technologies
We and our service providers use cookies, web beacons, pixels, session replay/screen capture, and similar technologies to collect information and personalize your experience with our Services.
We use these technologies in order to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences. Cookies are small text files that are placed on your computer or mobile device when you visit a site that enable us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Services you have visited; (iv) enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions.
As we adopt additional technologies, we may also gather information through other methods. Please note that you can change your settings to notify you when a cookie is being set or updated or to block cookies altogether. For more information, please consult the “Help” section of your browser (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). Please note that by blocking, disabling, or managing any or all cookies, you may not have access to certain features or offerings of the Services. For more information about our use of cookies, please see our Cookie Notice.
Children’s Information
The Services are not directed to children whose age:
is under the age of 13 years;
makes it illegal to process their personal data; or
requires parental consent to process their personal data.
We do not knowingly collect or use personal data from children who meet those criteria. If you're under the age of 13 years, please do not use the Services, and do not provide any personal data to us. We may offer a specific service dedicated to children and your use of that service will be subject to the privacy policy governing that service.
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. If you live in the EU and are under the age of 16 years, please do not use the Services, and do not provide any personal data to us.
We also comply with other age restrictions and requirements in accordance with applicable local laws.
If you're a parent of a child under the age of 13 or 16, as applicable, and become aware that your child has provided personal data to Gropino, please contact us. If we learn that we've collected the personal data of a child under the age of 13 or 16, as applicable, we'll take reasonable steps to delete the personal data. This may require us to delete the Gropino account associated with that personal data.
Your Rights
You have certain rights regarding the collection and processing of Personal Data. You may exercise these rights, to the extent they apply to you, by contacting us at the information provided at the end of this Privacy Policy, or by following instructions provided in this Privacy Policy or in communications sent to you.
Your rights vary depending on the laws that apply to you, but may include:
The right to know whether, and for what purposes, we process your Personal Data;
The right to be informed about the Personal Data we collect and/or process about you;
The right to learn the source of Personal Data about you we process;
The right to access, modify, correct, and delete Personal Data about you (see the “Accessing, Modifying, and Correcting Collected Personal Data” section below for more information);
The right to know with whom we have shared your Personal Data, for what purposes, and what Personal Data has been shared (including whether Personal Data was disclosed to third parties for their own direct marketing purposes);
The right to withdraw your consent, where processing of Personal Data is based on your consent; and
The right to file a complaint with a supervisory authority located in the jurisdiction of your habitual residence, place of work, or where an alleged violation of law occurred.
We may reject requests that are unreasonable or not required by law, including those that would be extremely impractical, could require disproportionate technical effort, or could expose us to operational risks such as free trial fraud. We may retain information as required or permitted by applicable laws and regulations, including to honor your choices, for our billing or records purposes, and to fulfill the purposes described in this Privacy Policy. We take reasonable measures to destroy or de-identify personal information in a secure manner when it is no longer required.
We currently do not collect household data. If all the members of a household make a request under this Policy, we will respond as if the requests are individual requests.
Please note, if you do not have a Gropino account we will not have enough information about you to verify your requests under this Policy, as we do not keep sufficient information necessary to reidentify and link you to a prior visit to Gropino where data may have been collected. As such, we will be unable to verify and honor your requests. You may make a verifiable consumer request related to your personal information twice per 12-month period.
If you are a California consumer, please see our California Consumer Privacy Act (CCPA) Privacy Notice by clicking here or simply scrolling down. See “Privacy Notice to Residents of Colorado, Connecticut, Virginia, and Utah,” “Privacy Notice for Residents of Nevada,” and “Your European Union and UK Privacy Rights,” for more information about certain legal rights.
Accessing, Modifying, and Correcting Collected Personal Data
We strive to maintain the accuracy of any Personal Data collected from you, and will try to respond promptly to update our records when you tell us the information in our records is not correct. If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by making changes to your Profile. You can request that we correct or supplement such data by emailing help@gropino.com.
Depending on the laws that apply to you, you may obtain from us certain Personal Data in our records. If you wish to access, review, or make any changes to Personal Data you have provided to us through the Services, please submit a request through our Online Form, or email us at help@gropino.com from the email address that you believe is associated with your Gropino account.
Data Erasure
In some jurisdictions, you can request that your personal information be deleted. Please note that if you request deletion of your personal information, or if your account is suspended, terminated, or voluntarily closed:
We may retain your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend a Gropino account for fraud or safety reasons, we may retain information from that account to prevent that member from opening a new account in the future.
We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, we may keep information for tax, legal reporting, and auditing obligations.
Some copies of your information (e.g., log records) will remain in our database, but are disassociated from personal identifiers.
Because we take measures to protect data from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
Please see “Other Users” below for important information on how users on our platform may continue to have access to your data.
Requests Made Through Agents
You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.
Your European Union and UK Privacy Rights
In addition to the above-listed rights, European Union and United Kingdom privacy law provides individuals with enhanced rights with respect to their Personal Data. These rights may include, depending on the circumstances surrounding the processing of Personal Data:
The right to object to decisions based on profiling or automated decision-making that produce legal or similarly significant effects on you;
The right to request restriction of processing of Personal Data or object to processing of Personal Data carried out pursuant to (i) a legitimate interest (including, but not limited to, processing for direct marketing purposes) or (ii) performance of a task in the public interest;
In certain circumstances, the right to data portability, which means that you can request that we provide certain Personal Data we hold about you in a machine-readable format; and
In certain circumstances, the right to erasure and/or the right to be forgotten, which means that you can request deletion or removal of certain Personal Data we process about you.
To exercise any of these rights, please submit a request through our Online Form, or email us at help@gropino.com from the email address that you believe is associated with your Gropino account. In the request, please specify which right you are seeking to exercise and the scope of the request.
Your Choices
You have choices about certain information we collect about you, how we communicate with you, and how we process certain Personal Data. When you are asked to provide information, you may decline to do so; but if you choose not to provide information that is necessary to provide some of our Services, you may not be able to use those Services. In addition, it is possible to change your browser settings to block the automatic collection of certain information.
Communications Opt-Out
We may send promotional emails from time to time. If you are located in the European Union, we will not send promotional emails without your consent. You can opt-out of receiving promotional emails from us at any time by clicking on the unsubscribe link in the emails. Please note that you cannot opt-out of non-promotional emails, such as those about your account, transactions, servicing, or our ongoing business relations. In addition, if you downloaded our app and opted-in to receive push notifications on your device, you can opt-out at any time by adjusting the permissions in your device or uninstalling our app.
Location Information
If you want to limit or prevent our ability to receive location information from you, you can deny or remove the permission for certain Services to access location information or deactivate location services on your device. Please refer to your device manufacturer or operating system instructions for instructions on how to do this.
Cookies and Web Tracking
Consult our Cookie Notice for more information about how to control and/or opt out of certain web tracking technologies.
Additional Information
Interpretation
Any version of this Privacy Policy in a language other than English is provided for convenience. If there is any conflict with a non-English version, you agree that the English language version will control.
Other Users
Other users of the Service or the public may have access to your Personal Data when you choose to make your profile or other personal information available to them through the Service, such as when you provide comments, reviews, survey responses, or other content. We do not control how other users or third parties use any personal information that you make available to such users or the public. Please be aware that any information you post publicly can be cached, copied, screen captured, or stored elsewhere by others (e.g., search engines) before you have a chance to edit or remove it.
California Consumer Privacy Act (“CCPA”) Privacy Notice
This Privacy Notice applies to California consumers and supplements the Privacy Policy.
Personal Information We Collect
We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“CCPA Personal Information”). We have collected the following categories of CCPA Personal Information from consumers within the last twelve (12) months:
Category Personal Data Collected
Identifiers First name, last name, postal address, unique personal identifier, online identifier, IP address, email address, alias, state, city, country, phone number, account name, social media profiles, or other similar identifiers
California Customer Records Personal Information Categories
First name, last name, postal address, credit card number, debit card number, or any other financial information.
If you are a Teacher, you can link your PayPal, Stripe, or other payment account to the Services to receive payments. When you link a payment account, we collect and use certain information, including your payment account email address, account ID, physical address, or other data necessary for us to send payments to your account. In some instances, we may collect ACH or wire information to send payments to your account. In order to comply with applicable laws, we also work with trusted third parties who collect tax information as legally required. This tax information may include residency information, tax identification numbers, biographical information, and other personal information necessary for taxation purposes.
Some personal information included in this category may overlap with other categories.
Characteristics of Protected Classifications Under California or Federal Law Age, race, national origin, physical or mental disability, sex (including gender, gender identity, gender expression), sexual orientation, veteran or military status of teachers only
Commercial Information Records of services purchased
Internet or Other Similar Network Activity Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement
Geolocation Data Our online services don’t collect precise geolocation data from GPS sensors. However, we do collect IP addresses from which we can determine your general location.
Sensory Data Video recordings
Professional or Employment-Related Information Employment History, Request for Leave
Sensitive Personal Information Race and sexual orientation of teachers only
Uses of CCPA Personal Information
We use categories of CCPA Personal Information listed above for the purposes noted in the “How We Use the Personal Data We Collect About You” section of our Privacy Policy.
Categories of CCPA Personal Information disclosed for a business purpose
We disclose the categories of CCPA Personal Information listed below for business purposes. This table summarizes those categories and the third-party recipients of those categories, and also specifies where we are selling or sharing that information with those third-party recipients in certain instances. (Please see the “Disclosing Your Personal Data” section of our Privacy Policy for additional details that may be of interest to you.)
Category Category of Third-Party Recipients Usage
Identifiers Teachers, payment processors, analytics service providers, ad networks and marketing tools Sold to or shared with (as defined under California law) analytics service providers or ad networks and marketing tools in certain instances
California Customer Records Personal Information Categories Teachers, payment processors Not sold to or shared with (as defined under California law) third-party recipients
Characteristics of Protected Classifications Under California or Federal Law; Sensitive Personal Information (applicable to teachers only) Vetted collaboration partners, such as media partners Not sold to or shared with (as defined under California law) third-party recipients
Internet or Other Similar Network Activity Analytics service providers, ad networks and marketing tools, providers of advertising services Sold to or shared with (as defined under California law) analytics service providers or ad networks and marketing tools in certain instances
Geolocation Data Analytics service providers, ad networks and marketing tools, providers of advertising services Sold to or shared with (as defined under California law) analytics service providers or ad networks and marketing tools in certain instances
Inferences Drawn From Other Personal Information Analytics service providers Sold to or shared with (as defined under California law) analytics service providers or ad networks and marketing tools in certain instances
Sources of CCPA Personal Information
We explain our sources of information in the “Personal Data We Collect About You” section of our Privacy Policy. For ease of reference, in regard to CCPA Personal Information these are:
Directly from you: For example, when you provide it to us to sign up for a Gropino account, interact with our customer service, or participate in surveys or marketing promotions, as well as information you provide when you choose to provide taste preferences or account settings (including preferences set in the “Account” section of our website).
Automatically or indirectly from you: For example, through and as a result of your use of and access to the Services, including through our mobile application.
Business and marketing partners or service providers: For example, online interactions you may have with our joint marketing partners and event co-sponsors, online identity and fraud verification services, social media sites, and analytics providers.
Sales and Sharing of Personal Information
We use cookies and/or similar tracking technologies that enable certain advertising networks, social media companies, analytics services, and other third-party businesses to collect and use your personal information directly from your browser or device when you visit or interact with our Service or otherwise engage with our platform online. In some cases, we may upload CCPA Personal Information to certain of these partners for advertising or analytics purposes.
Your California Privacy Rights
California’s “Shine the Light” law permits users of the Services who are California residents to request certain information regarding its disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please submit a request through our Online Form, email us at help@gropino.com from the email address that you believe is associated with your Gropino account, or write to us at the address listed below.
The CCPA provides our users who are California residents the following rights with regard to CCPA Personal Information:
Right to Know: You have the right to request that we disclose certain information to you about the CCPA Personal Information we collected, used, disclosed, and sold about you in the past 12 months. Please note that you may only submit a request to know twice within a 12-month period. You may request to know any or all of the following:
The categories of CCPA Personal Information we have collected about you;
The categories of sources from which the Personal Data was collected;
The categories of third parties to whom the CCPA Personal Information was disclosed;
The business or commercial purpose for collecting, selling, or sharing the CCPA Personal Information; and
The specific pieces of CCPA Personal Information we have collected about you.
Right to Deletion: You have the right to request that we delete the CCPA Personal Information we collected from you and maintained, subject to certain exceptions.
Right to Correct: You have the right to request that we correct inaccurate CCPA Personal Information that we maintain about you.
Right to Opt Out of Sales and Sharing: You have the right to opt out of our “sale” or “sharing” of your CCPA Personal Information. Please see above for how to exercise that right.
Right to Non-Discrimination: You have the right not to receive discriminatory treatment by us for the exercise of any of your rights.
The CCPA also allows you to limit the use or disclosure of your “sensitive personal information” (as defined in the CCPA and listed above) if your “sensitive personal information” is used for certain purposes. If we indicate above that we collect your “sensitive personal information,” you may opt out of our use or disclosure of that information by completing this form or by emailing us at legal@gropino.com.
You can exercise these rights by contacting us as specified in the “Contact Us” section at the end of this Policy. You can also designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and we may verify your identity directly. Please note that the rights listed above are subject to certain exceptions.
Retention
We retain CCPA Personal Information in accordance with the “Data Erasure” section above.
Privacy Notice to Residents of Colorado, Connecticut, Virginia, and Utah
The disclosures in this section apply solely to individual residents of the states of Colorado, Connecticut, Virginia, and Utah. Privacy laws in these states give residents certain rights with respect to their personal data, when they take effect over the course of 2023. Those rights include:
Right to Request Access: You have the right to access and obtain a copy of your personal data that we hold about you.
Right to Request Deletion: You have the right to request that we delete personal data that we hold about you.
Right to Correct: You have the right to correct inaccuracies in your personal data.
Right to Opt Out of Sales and Use of Personal Data for Targeted Advertising Purposes: You may opt out of our “sale” of your personal data and our processing of your personal data for the purposes of “targeted advertising,” as such terms are defined in applicable privacy laws.
Right to Portable Data: You have the right to request that we provide you a copy of personal data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another business, where our processing is carried out by automated means.
To submit a request to exercise your access, deletion, or correction privacy rights, please submit a request through our Online Form, or email us at help@gropino.com from the email address that you believe is associated with your Skillshare account. In the request, please specify which right you are seeking to exercise and the personal data with respect to which you want to exercise this right.
Please note that these rights are subject to certain exceptions. If you are a Colorado, Connecticut, or Virginia resident and we deny your request to exercise any of the rights above, you may appeal our denial of your request by contacting us via one of the contact methods specified at the end of this Policy.
Privacy Notice for Residents of Nevada
For residents of the State of Nevada, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of sales of certain covered information that a website operator has collected or will collect about the resident. We do not currently sell covered information.
Changes to Our Privacy Policy
This Privacy Policy replaces all previous disclosures we may have provided to you about our information practices with respect to the Services. Our Services may change from time to time. As such, we reserve the right, at any time, to modify, alter, and/or update this Privacy Policy, and any such modifications, alterations, or updates will be effective upon our posting of the revised Privacy Policy. We will use reasonable efforts to notify you in the event material changes are made to our processing activities and/or this Privacy Policy, such as by posting a notice on the Services or sending you an email. The date this Privacy Policy was last updated is identified at the top of the page. Your continued use of the Services following our posting of any revised Privacy Policy will constitute your agreement of the amended Privacy Policy.
Contact Us
If you have any questions about this Privacy Policy or our data practices generally, please contact us using the following information:
Please contact help@gropino.com if you need to access this Policy in an alternative format due to having a disability.