Effective Date: May 24, 2018
Any information relating to taking courses, including, without limitation, interchanges with the course instructors, other Students, answers, essays and other items submitted to satisfy the course requirements, is referred to as “course Information.” Dubata allows you to enroll in and take online courses on a variety of topics which are taught by Teachers where, among other things, you will see reviews for courses by other students of the course.
We self-certify compliance with the following: the U.S. – E.U. Safe Harbor Framework and U.S. – Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from European Union member countries and Switzerland. Dubata.com has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view the Dubata.com certification, please visit http://www.export.gov/safeharbor.
Please read the information below:
- Information we collect about you
- Where we store data
- How we use your information
- Disclosure of your information
- Information we collect through Automated means
- Canceling your account or deleting your personally identifiable information
- Choices regarding control of your personally identifiable information
- Keeping your information secure
- Mobile Analytics
- Links to third party web sites and advertisers
- California Privacy Rights
- Communities, forums, chat rooms, and message boards
- Social Media features
- A Note to Users Outside the U.S. and the EU
- How do you contact us with questions?
1. INFORMATION WE COLLECT ABOUT YOU
We collect several types of information about visitors and/or users of our Services. We may collect this information either directly when you provide it to us or automatically as you navigate through the Websites..
Dubata does not currently retain credit card numbers internally. We partner with payment providers such as PayPal, Stripe and others. All direct payment gateways like Paypal, 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.
We may also collect your Internet Protocol (‘IP’) address. We use your IP address to diagnose problems with our servers, software, to administer our Services and to gather demographic information.
The following examples are provided to help You better understand the information we may collect through Your use of the Services:
(a) Information Received Through Your Third Party Platform Account
When You use Our Services through a Third Party Platform, such as Facebook, You allow us to access and/or collect certain information from your Third Party Platform profile/account (such as your Facebook or Google account) as permitted by the terms of your agreement and your privacy settings with the Third Party Platform. The information you allow us to access and collect varies depending on the site or service you use, as well as the terms of the Third Party Platform and your privacy setting thereon. By way of example only, We may access and/or collect some or all of the following information from Your Third Party Platform account when You register or use the Services on or through a Third Party Platform:
- Your full name
- Your profile picture or its URL
- Your User ID number, which is linked to publicly available information such as Your name and profile photo
- The login e-mail address
- Your physical location and that of Your access devices, including any Wireless Device
- Your gender
- Your birthday
(collectively “Third Party Platform Information”)
(b) Information Received Through Your Wireless Device: Push Notifications
If you use the Services on or through a Wireless Device, we may, in accordance with the terms of any applicable agreement with the Wireless Device carrier (and as allowed by your privacy settings) collect certain information such as your unique device identifier (a number automatically assigned to your mobile or wireless device), device type, operating system version and information You may choose to provide or share, such as Your e-mail address (collectively “Mobile Information”).
We do not ask for, access or track any precise location-based information from Your Wireless Device.
(c) Information You Provide To Us Directly
When You sign up for the Services (including through a Third Party Platform) We will collect any information You provide to Us directly such as the following:
Registration Information: In order to use certain features of the Services, such as purchasing or registering for a course, You are required to register for an Account, and in that case, We will collect and store any registration You share with Us, such as Your date of birth, age, e-mail address, password and other information, your company’s name, e-mail address as well as telephone and address information, that helps us to confirm Your access to Your Account and understand more about who You are (“Registration Information”).
Profile Information: For some Services, You may also have the option of providing additional information about Yourself (“Profile Information”) to create a User profile (“Profile”) that will be publicly viewable by others. You should exercise care and caution in creating Your Profile as Your Profile, including Your Profile Information, Master Badges, and Certificates will be publicly viewable to others. Dubata is not responsible for the information you supply in Your Profile/and or the manner in which it is used by others.
You hereby grant Dubata a non-exclusive right and license to reproduce, distribute, publicly perform, offer, market and otherwise use and exploit the Submitted Content and Shared Content.
You hereby also consent to Dubata providing Registration Information and/or Profile Information to Teachers as part of the course Information when you enroll in a course. Teachers may have other uses for course Information. It is Your responsibility when You enroll in a course to confirm what uses the Teacher will make of Your Profile and Registration Information. Dubata does not control these uses and is therefore not liable for the uses by Teachers.
(d) Payment Information
If you make any purchases through our Services, such as courses, we may collect certain information regarding your purchase (such as your name and zip code) as necessary to process your order, and you will be required to provide certain payment and billing information directly to our payment processing partners, including but not limited to your name, credit card information, billing address and zip code. We do not directly access, store or collect your credit card information, and we will not use the payment information we collect except as needed to fulfill your purchase and/or communicate with you regarding your transaction.
(e) Children’s Policy
We do not knowingly collect personal information from children under 13. Children under the age of 13 should not use or attempt to use our Websites or Services and if you are under 13, please do not attempt to use our Services or send any information about yourself to Dubata. If we learn that we have collected personal information from a child under 13, We will delete such information.
Parents who believe that Dubata might have any information from or about a child under the age of 13 may submit a request to email@example.com and request that the information be removed.
2. WHERE WE STORE DATA
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our service providers. Such staff maybe engaged in, among other things, the fulfillment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.
3. HOW WE USE YOUR INFORMATION
We use information held about you in the following ways:
- Providing, administering, and facilitating Your use of the Services, including the display of customized content and/or targeted advertising;
- Marketing our products and/or services to you, including sending you offers, promotions information, newsletters, email campaigns, and communications regarding new, improved or existing products, contests and/or sweepstakes;
- Resolving site problems; handling or responding to customer support questions and issues;
- Processing or fulfilling your request(s) and/or order(s) for courses, products, services, information or features;
- Enabling User-to- User communication and interaction and soliciting input and feedback to improve User experience;
- Managing your Account preferences, establishing your Profile and Registration Information;
- Monitoring the technical functioning of the Services and network;
- Developing new and/or improved, products, services or offerings;
- Providing you with news and newsletters;
- To create, review, analyze and share Aggregate Information;
- Identifying, researching, and protecting against any actual, potential or threatened misuse, unauthorized use, or unwanted use of any of the Services, including but not limited to researching any claims made by or about other Users and/or about the Services, and such efforts of which may include information provided from third-party sources;
- Third party hosting of the Services;
- Analyzing trends and User traffic;
- Marketing, processing or fulfillment of promotions administered or sponsored by Dubata;
- Resolving disputes;
- Troubleshooting errors or issues with any of the Services;
- Tracking purchases and usage information;
- Communicating with you concerning Your Account;
- Asking you to participate in surveys about Our Services; or
If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale to you.
If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this.
If you use the Contact Us form on our site, we will respond to your inquiry and delete the information provided after your request has been fulfilled.
4. DISCLOSURE OF YOUR INFORMATION
(a) We provide some of our Services through contractual arrangements with service providers and other third parties. We and our service partners use your Personally Identifiable Information to operate our Websites and to deliver Services. For example, we must release your credit card information to the card-issuing bank to confirm payment for products and services purchased on our Websites; release your address information to the delivery service to deliver products that you ordered; and provide order information to third parties that help us deliver the services.
(c) In the event that Dubata decides to sell all or part of its stock or assets or enter into a merger, we reserve the right to include Personally Identifiable Information and Non-Personally Identifiable Information among the assets transferred to the acquiring or surviving company.
(d) We may provide Non-Personally Identifiable Information about our customers’ sales, traffic patterns, and related Website information to third party advertisers.
(e) Parents are able to consent to the use of their child’s Personally Identifiable Information without having to consent to the Website’s disclosure of the child’s Personally Identifiable Information to third parties, as we do not share Personally Identifiable Information of children under the age of 13 with any third parties (other than those service partners who help us provide the Dubata service to you).
5. INFORMATION WE COLLECT THROUGH AUTOMATED MEANS
6. CANCELING YOUR ACCOUNT OR DELETING PERSONALLY IDENTIFIABLE INFORMATION
1. Deactivating Your Account
If you are a Student, and wish to delete Your Student Account, You may do so by following the steps provided in the following Student Delete Instructions page.
If you are an Teacher, and wish to delete Your Teacher Account, You may do so by following the steps provided in the following Teacher Delete Instructions page.
Should you require any assistance or encounter any difficulty in deleting your Account, you may also contact us via email at firstname.lastname@example.org or via our Support Center, and we will make efforts to respond to your request within 24 hours.
2. Account Terminated or Deleted
Please be aware that even after your Account is terminated or deleted some or all your information may still remain visible to others, including but not limited to any information that has been: (a) incorporated into others User’s content, comments, postings, submissions, including but not limited to course comments ; (b) copied, stored or disseminated by other Users; (c) shared or disseminated by You or others such as in a Public Posting; or (4) posted on a Third Party Platform. A request to delete and/or termination of your Account will not result in the removal of information collected and already put in aggregate form or information that cannot, in Our sole discretion, be removed without undue burden to Dubata. Dubata is not able and/or obligated to remove any of your information from a Third Party Platform.
Moreover, please be aware that even after you delete your Account or your Account is terminated, your information, is not deleted in its entirety from Our servers and may not be deleted from servers of the Third Party Platform You use to access Our Services. We may retain backup copies of your information, including personal information on our servers or databases (and/or any authorized third party servers or databases we use) to assist with any legal obligations, resolve disputes, and enforce Our agreements.
7. CHOICES REGARDING CONTROL OF YOUR PERSONALLY IDENTIFIABLE INFORMATION
You can access some of the information that we collect about you or your child. For example, by logging in to your account, you can access information regarding recent orders from the Websites; Personally Identifiable Information; communication preferences; and payment settings.
With respect to your communications preferences, you can unsubscribe from newsletters by following the instructions included in the newsletter you receive or you can log into your account and update your newsletter and email subscription options. If your e-mail address has changed and you would like to continue to receive newsletters, you will need to access your account and update your e-mail address information in your account and sign-up again for the newsletter. Occasionally we may send out e-mails concerning website disruptions.
If you indicated upon registration that you are interested in receiving offers or information from us and our partners, we may occasionally send you direct mail about products and services that we feel may be of interest to you. Only Dubata.com (or agents working on behalf of us and under confidentiality agreements) will send you these direct mailings, and only if you did not later ‘opt-out’ of such offers.
We do not send unsolicited commercial e-mails (“spam”). We offer commercial e-mail recipients the opportunity to opt-out of further communications in every e-mail. Please note that we may not include the opt-out information in non-commercial Service e-mails (i.e., e-mails concerning your order, the Website Terms of Service, etc.).
You also have choices with respect to cookies, as described below. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies some parts of our Websites may not work properly in your case.
8. KEEPING YOUR INFORMATION SECURE
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using Secure Sockets Layer (SSL) technology.
To make online purchases you must use an SSL-enabled browser in order to protect the confidentiality of your personal and credit card information while it is transmitted over the Internet.
Access by you to your account is available through a password and/or unique user name selected by you. This password is encrypted. We recommend that you do not divulge your password to anyone, that you change your password often using a combination of letters and numbers, and that you ensure you use a secure web browser. We cannot be held accountable for activity that results from your own neglect to safeguard the secrecy of your password and user name. If you share a computer with anyone, you should always log out of your account after you are finished, in order to prevent access to your information from subsequent users of that computer.
Please notify us as soon as possible if your user name or password is compromised by emailing email@example.com.
Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personally Identifiable Information, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity and privacy of any and all information and data exchanged between you and us through this Website cannot be guaranteed and we shall have no liability to you or any third party for loss, misuse, disclosure or alteration of such information; and (c) any such information and data may be viewed or tampered with in transit by a third party.
In the unlikely event that we believe that the security of your Personally Identifiable Information in our control may have been compromised, we will notify you as promptly as possible under the circumstances. To the extent we have your e-mail address, we may notify you by e-mail and you consent to our use of e-mail as a means of such notification.
9. COOKIES AND OTHER TECHNOLOGIES
What is a cookie? A cookie is a small data text file, which a website stores on your computer or mobile device (if your Web browser permits) that can later be retrieved to identify you to us.
Our cookies store randomly assigned user identification numbers, the country where you are located, and your first name to welcome you back to our Websites. The cookies make your use of the Websites easier, make the Websites run more smoothly, and save your logged-in state so that you do not have to log in each time that you visit the Websites.
You can disable and/or delete all types of cookies by using your browser settings. Cookies are generally easy to disable and/or delete but how you do so varies from browser to browser. The “help” function within your browser should tell you how to do it. The best way may be to close your browser and then search for “cookie folder” or “cookie manager” or simply “cookie”. Please also visit www.allaboutcookies.org for more information about cookies and how to disable them. If you do disable cookies, our Websites will not recognize you and you may not have access to all portions of the Websites.
What are clear gifs? Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the full-stop or period at the end of this sentence.
What is a Flash cookie? Local storage objects, also known as “Flash cookies”, are similar in function to browser cookies in that they store some information about you or your activities on our Websites. We use Flash cookies in certain situations where we use Flash to provide some content such as video clips or animation. The options within your browser may not prevent the setting of Flash cookies. To manage Flash cookies please click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.
Dubata uses the following types of cookies:
Preferences. We use preferences cookies to remember information about Your browser and how you prefer to use Our Service, i.e. to remember Your preferred settings that affect the experience of how Our Services look to You or behave when You access and/or use them, such as Your preferred language. Preference cookies make Your experience of interacting with Our Services more functional and customized to suit Your preferences.
Security. We use security cookies to enable You to log-in and access Our Service, to protect Your Account against fraudulent log-ins by others, and help detect, fight, and protect against abuse or unauthorised usage of Your Account.
Functional. We use functional cookies to make the experience of using Our Services better, like remembering the volume You like your videos to play at.
Session State. We use session cookies to collect information about how You interact with Our Service, to help Us improve Our Services We provide You as well as improve Your browsing experience. We also use session cookies to remember Your log-in details and to be able to process Your purchases of courses. These are deemed strictly necessary to the working of the Services. If these are disabled, then various functionalities of our Services will be broken.
Analytics. We use analytics cookies, such as Google Analytics, to better understand how Our Services are being used in order to improve User experience. Such User data generated is all anonymous and not linked to personally identifiable information. You can find out more about Google’s position on privacy as regards its analytics service at http://www.google.co.uk/intl/en/analytics/privacyoverview.html .
10. MOBILE ANALYTICS
We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information such as how often you use the App, the events that occur within the App, aggregated usage, performance data, and where the App was downloaded from. We do not link the information we store within the analytics software to any Personally Identifiable Information you submit within the App.
11. LINKS TO THIRD PARTY WEB SITES AND ADVERTISERS
12. CALIFORNIA PRIVACY RIGHTS
If you are a California resident and have provided us with Personally Identifiable Information, California law gives you the right to request and receive from us, once per calendar year, information as to how we have shared your Personally Identifiable Information with third parties for their direct marketing purposes. If applicable, such information would include a list of names and addresses of all third parties with whom such information was shared during the prior calendar year as well as a list of the categories of Personally Identifiable Information shared. To make such a request, please send an email to firstname.lastname@example.org and include the phrase “California Privacy Request” in the subject line. Your request must also include your name, physical mailing address and email address. We will respond to you within thirty days of receiving such a request.
Note, that we will not share your Personally Identifiable Information with third parties for their marketing purposes without obtaining your prior consent. Moreover, if you have granted us permission, such third parties’ use of your Personally Identifiable Information will be subject to their privacy policies. You should contact those entities directly regarding any communications you may receive from them, including, if you later decide that you no longer want that third party to use your personal information.
14. COMMUNITIES, FORUMS, CHAT ROOMS, AND MESSAGE BOARDS
If you or your child choose to disclose Personally Identifiable Information on communities, message boards, forums, and the like, which may be accessible via the Websites, you should be aware that such information, along with any information disclosed in your communication, can be collected and used by third parties and may result in unsolicited messages from third parties. To request removal of your personal information from our blog or community forum, contact us at email@example.com. You acknowledge and accept that any submissions to chat rooms or other public areas on the Websites are accessible to all third parties. If you do not want yours or your child’s comments to be viewed by third parties, you are advised not to make any submissions. Ultimately, you are solely responsible for all activity conducted by you via communities, forums, message boards, chat rooms, etc. Please be careful and responsible whenever you are online.
15. SOCIAL MEDIA FEATURES
16. A NOTE TO USERS OUTSIDE THE U.S. AND THE EU
Dubata stores information about visitors to Our Services and users on servers located in the United States. If You are using the Services from outside the United States and the European Union, please know the data and personal information you submit will be transferred to and stored in servers in the United States or other countries. The data protection and other laws of the United States and/or other countries might not be as comprehensive as those in Your country. By submitting Your data and/or using Our Services, You consent to the transfer, storing, and processing of Your data in and to the United States.
Personal data collected within Switzerland and the European Economic Area (“EEA”) may be transferred to, and stored at, a destination outside of Switzerland and the European Economic Area (“EEA”). The data we hold may also be processed by employees operating outside of Switzerland and the EEA who work for Us or one of our affiliates or for one of Our vendors.
Such staff may be engaged in, among other things, (i) the processing of transactions and Your payment details and (ii) the provision of support services. By submitting Your personal data or engaging in Dubata courses, You agree to this transfer, storing or processing.
17. HOW DO YOU CONTACT US WITH QUESTIONS?
P.O. Box 38
Durham, NC 27702
Attn: Business Policy Affairs
You may also contact us by email at firstname.lastname@example.org.