Empiricus Akermo - Privacy Policy

Last Modified: January 15th, 2021
This privacy policy (“Privacy Policy”) is designed to inform you about EMPIRICUS AKERMO US LLC (“EMPIRICUS AKERMO,” “we,” “us,” or “our”) policies and procedures for collecting, using, and disclosing your information in connection with your use of the EMPIRICUS AKERMO service. EMPIRICUS AKERMO provides a tattoo E-learning platform (the “Service”) designed to teach people tattooing techniques & design (“Students”).
This Privacy Policy governs your access of the Service, regardless of how you access it, and explains what data we collect when you use the Service, why we collect the data, how it is used, and your rights and choices. 
1. INFORMATION WE COLLECT
When you interact with the Service and in connection with our events, and sales and marketing activities, we collect information that alone or in combination with other information could be used to identify you (“Personal Data”), as described below:
When you register an account as an Learner, you may be asked to provide Personal Data including without limitation:
Identity Data includes first name, maiden name, last name, username or similar identifier, title, voice, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Profile Data includes your username and password, images provided to represent you, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
You may also choose to submit Personal Data to us when you send us an email or use any interactive features that we may make available on the Service.
2. HOW WE USE INFORMATION
Using our Learning Platform 
We use account-related data provided by Learners in connection with the sign-up, use, or support of the Learner account (such as usernames, email address and billing information) to provide you with access to the Service, contact you regarding your use of the Service, or to notify you of important changes to the Service. Such use is necessary for the performance of the contract between you and us.
Provide Information; Respond to Requests
When you ask for information about the Service (for example, when you request a demo or ask us to send you offers or price information), we will use your contact information to respond to your request.
Sending Marketing Communications
Where required by applicable law (for example, if you are an EU data subject), we will only send you marketing information by email, or contact you by phone, if you consent to us doing so at the time you provide us with your Personal Data. 
When you provide us with your consent to be contacted for marketing purposes, you have the right to withdraw your consent at any time by following the instructions to “opt-out” of receiving marketing communication in each marketing email we send you. In addition, if at any time you do not wish to receive future marketing communications or wish to have your name deleted from our mailing or calling lists, please contact us at info@oscarakermo.com. 
Please note that if you opt out from marketing communications, we may still contact you regarding issues related to our Service and to respond to your requests.
For our Legitimate Business Interests
We use data relating to your use of and interaction with the Service for certain legitimate business interests, which are the following:
to personalize and improve your access to and use of the Service (including to increase our Service’s functionality, product features, and user-friendliness);
to conduct analytics and report on industry trends on content usage and performance;
to meet our corporate and social responsibility objectives;
for internal business/technical operations, including troubleshooting, data analysis, testing, to prevent fraud or criminal activity, misuses of our products or services and ensure the security of our IT systems, architecture, and networks.
This use of your Personal Data is necessary for our legitimate interests in understanding how our Service are being used by you and to improve your experience on it. 
3. INFORMATION SHARING AND DISCLOSURE
A. Employees, Service Providers, Business Partners, and Others
We will disclose your Personal Data to our employees as necessary to deliver the Service, and we may use certain third party companies and individuals to help us provide, support, analyze, and improve the Service (such as providers of data storage services, maintenance services, payment processing (Stripe), database management, digital business services (Kajabi), providers of analytics services who help us understand how you use and interact with the Service (Clickfunnels), providers of digital advertising services, providers of CRM, marketing, and sales software solutions. These third parties may have access to your Personal Data for the purpose of performing these tasks on our behalf and pursuant to our instructions.
B. Compliance with Laws and Law Enforcement Requests
We may disclose to parties outside the data stored in your EMPIRICUS AKERMO account and information about you that we collect when we have a good faith belief that disclosure is reasonably necessary to (a) comply with a law, regulation, or compulsory legal request; (b) protect the safety of any person from death or serious bodily injury; (c) prevent fraud or abuse of EMPIRICUS AKERMO or its Learners; or (d) to protect EMPIRICUS AKERMO' property rights. 
C. Business Transfers
If we are involved in a merger, acquisition, bankruptcy, or sale of all or a portion of our assets, your information may be transferred as part of that transaction, but we will notify you of any change in control or use of your Personal Data or Content, or if either become subject to a different Privacy Policy. We will also notify you of choices you may have regarding the information.
4. CHANGING OR DELETING YOUR INFORMATION
If you are a registered Learner, you may review, update or correct the Personal Data in your account. If you would like to delete your account, please contact us as indicated below. If your Personal Data has been shared outside of our Service by other Learners, Subscribers or any third parties and not directly by us, we cannot change or delete this Personal Data out of our control. 
We will retain your Personal Data for as long as is necessary for the purposes set out in this Privacy Policy or for our Services, for as long as your account is active, or as needed to provide you the Service or for the duration required by law, whichever is the longer. If you wish to delete your account or if your account has been inactive for longer than 3 months, we will delete your account information. Please note that we may retain, use or disclose your information as necessary to comply with our legal obligations, to resolve disputes or enforce our agreements, and a legitimate business interest (such as for analytics purposes, safety, and security).
5. EU DATA SUBJECTS
A. Scope
This section applies solely to EU data subjects (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway and, where applicable, Switzerland). Our Privacy Policy describes why and how EMPIRICUS AKERMO collects, uses and stores your Personal Data, the lawful basis on which your Personal Data is processed, and what your rights and our obligations are in relation to such processing (please see “Your Rights” section below).
B. Data Controller
EMPIRICUS AKERMO is the data controller for processing of your Personal Data, but we act as a data processor for Personal Data that we process on behalf of our Learners. 
C. Your Rights
Subject to applicable EU law, you have the following rights in relation to your Personal Data:
Right of access: If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data along with certain other details. If you require additional copies, we may need to charge a reasonable fee.
Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your Personal Data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
Right to erasure: You may ask us to delete or remove your Personal Data, such as where our legal basis for the processing is your consent and you withdraw consent. If we shared your data with others, we will tell them about the erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data with so you can contact them directly. We may continue processing Personal Data where this is necessary for a legitimate interest in doing so, as described in this Privacy Policy.
Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it. We will tell you before we lift any restriction on processing. If we shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
Right to data portability: You have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so:
If we are relying on a legitimate interest to process your Personal Data — unless we demonstrate compelling legitimate grounds for the processing or
If we are processing your Personal Data for direct marketing.
Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing of your data before we received notice that you wished to withdraw your consent.
Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.
You may exercise your rights by contacting us as indicated under “Contacting Us” section below.
D. Legitimate Interest
“Legitimate interests” means our interests in conducting our business, managing and delivering the best Service to you. This Privacy Policy describes when we process your Personal Data for our legitimate interests, what these interests are and your rights. We will not use your Personal Data for activities where the impact on you overrides our interests, unless we have your consent or those activities are otherwise required or permitted by law.
6. SECURITY
The security of your information is important to us. We follow generally accepted standards to protect the Personal Data submitted to us, both during transmission and once we receive it. No method of electronic transmission or storage is 100% secure, however. Therefore, we cannot guarantee its absolute security. 
7. OUR POLICY TOWARD CHILDREN
Our Service is not directed to persons under 13. We do not knowingly collect Personal Data from children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Data without their consent, he or she should contact us and we will endeavor to delete it.
8. YOUR CALIFORNIA PRIVACY RIGHTS
Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., requests made in 2018 will receive information regarding 2017 sharing activities).
To obtain this information, contact us specifying that you want a “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response.
Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.
9. CHANGES TO OUR PRIVACY POLICY
This Privacy Policy may change from time to time. If we make a material change to this privacy policy, we will provide you with notice (for example, by email if you have provided your email address to us and your email address is current), and we may provide notice of changes in other circumstances as well. It is therefore important that you register with us and notify us if you change your email address. If you do not provide us with a current email address, you should regularly review this policy to ensure that you are informed of any changes.
10. CONTACTING US
If you have any questions about this Privacy Policy, please contact us at info@oscarakermo.com

Cookie Policy
Empiricus Akermo uses cookies and similar technologies on our Site and Services to operate and administer our Site and the Services, gather usage and performance data and give you a personalized experience with Empiricus Akermo. 
This Cookie Policy (“Cookie Policy”) provides information about how and when we use cookies and similar technologies for these purposes and the choices that you have. It forms part of Empiricus Akermo' Privacy Policy. Capitalized terms used in this Policy but not defined have the meaning set forth in our Privacy Policy.
1. COOKIES AND OTHER TECHNOLOGIES
A cookie is a piece of information sent to your browser from a website and stored on your computer’s hard drive. Cookies can help a website like ours recognize repeat users and allow a website to track web usage behavior. Cookies work by assigning a number to the user that has no meaning outside of the assigning website. For more details on cookies and similar technologies please visit All About Cookies.
Cookies can be stored on your computer for different periods of time. “Session cookies” only last for as long as the browser session and are deleted automatically once you close your browser. “Persistent cookies” cookies survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again. We use “persistent cookies” to save your registration ID and login password for future logins to the Services. We use “session ID cookies” to enable certain features of the Services, to better understand how you interact with the Services, and to monitor aggregate usage and web traffic routing on the Services.
We also use pixel tags (usually in combination with cookies), from the third parties described below, to get information about your usage of the Site and the Services and your interaction with email or other communications. Pixel tags are a technology similar to cookies that can be embedded in online content or within the body of an email for the purpose of tracking activity on websites (for example, to know when content has been shown to you), or to know when you have viewed particular content or a particular email message.
2. TECHNOLOGIES USED
We use cookies and similar technologies as described below:
 
Type/Purpose
Who serve them
Opt-Out
Strictly Necessary: Used to provide our Site and Services and use some of their features, such as the ability to log-in and access to secure areas. These cookies are essential for using the Site and the Services and without these cookies basic functionalities would not work.
Wistia, 
Clickfunnels
Because these cookies are strictly necessary to deliver the website and the services, you cannot refuse them.
Analytics: Used to recognize and count the number of Site visitors and see how they move around the Site (including number of page views, number of visitors, and time spent on each page). This helps us to improve the way our Site works, for example by making sure you can easily find what you need, and monitor the performance of our application in order to improve it.
Wistia, 
Facebook pixel, 
Active Campaign,
Google Analytics
You can block or delete these cookies by changing the browser settings as explained under the “Your Choices” section below.Some providers offer direct opt- out tools. 
Functionality: Used to Site and Services (such as collecting performance and error data, enabling customer support for users, for example offering live support chat). Some cookies may also allow us to conduct analytics.
Wistia, 
Clickfunnels
You can block or delete these cookies by changing the browser settings as explained under the “Your Choices” section below.
 
3. YOUR CHOICES
On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:
Internet Explorer
Mozilla Firefox
Google Chrome
Apple Safari
You may also manage or opt-out of cookies by using the links provided by the third parties described above.
Please note that if you reject cookies or turn cookies off, you may be unable to access certain parts of the Site or the Services and you may not be able to benefit from the full functionality of the Site or the Services. You may not decline pixel tags. However, they may be rendered ineffective by declining all cookies or modifying your browser settings to notify you each time a cookie is tendered and permit you to accept or decline cookies on an individual basis.