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Privacy Policy

GENERAL PRIVACY TERMS Cerebellum Academy values your privacy and is dedicated to safeguarding it. Along with our Terms and Conditions, this Privacy Policy explains how we collect, use, share, and store information when you use our Platform, as well as the reasons for collecting such information and the privacy rights and choices available to you regarding your information submitted to us. The terms ” Cerebellum Academy,” “we,” “us,” and “our” refer to Cerebellum Academy Private Limited and its affiliates, while “you,” “yours,” and “User(s)” refer to all users of our Platform, including Learners and Content Providers. By accessing and using our Platform, and agreeing to our Platform Terms, which include this Policy, our Terms and Conditions, and any other applicable rules, policies, or guidelines published on our Platform, you consent to the collection, use, disclosure, sharing, and storing of your information as described in this Policy. If you have already provided Personal Information to us or do not agree with how we collect, store, or use your Personal Information, you can modify or delete it in accordance with this Policy. Cerebellum Academy reserves the right to delete any information you provide or upload to our Platform that violates our Platform Terms and may revoke your access to the Platform accordingly. If you have any questions about this Policy, please contact us at privacy@cerebellumacademy.com. Any capitalized terms used but not defined in this Policy can be found in our Terms and Conditions
APPLICABILITY This Policy is relevant to all individuals who use our Platform. It is important to note that Cerebellum Academy, along with its holding, affiliate, and group companies, operates multiple platforms (referred to as “Group Platforms”) that offer various services related to technology solutions in the online and offline learning spaces. Each Group Platform has its own privacy policy, and as such, this Policy only applies to the collection of your information through our Platform. Please refer to the relevant Group Platform’s privacy policy to understand their specific privacy practices.
ACCESS You may access and view the Platform as a guest without the need to create an account or provide any Personal Information. Certain services may be available without registration, but you may need to provide certain Personal Information and other information to use those services. To access all the features and benefits of the Platform, creating an account is necessary. During registration, you will be required to provide certain Personal Information and other details, including whether you would like to receive promotional offers from Cerebellum Academy (which may be optional). Cerebellum Academy may request additional information from you in the future to customize the Platform and provide personalized information. For the purpose of rendering Services effectively and efficiently, Cerebellum Academy may keep records of telephone calls or emails received from or made by you for enquiries, feedback, or other purposes.
USE OF THE PLATFORM/SERVICES BY CHILDREN To register on our Platform, you must meet our “Age Requirements” as defined in our Terms and Conditions. If you are a Minor or Child who does not meet these requirements, you may not register on the Platform. However, your Parent may register on your behalf, agree to all Platform Terms, and provide access to you under their supervision. While some of our Services may require the collection of a Child’s Personal Information, we do not intentionally collect such information without the Parent’s consent. Our Platform is only intended to be accessed and used under the supervision of a Child’s Parent(s), and we assume that any Child’s Personal Information has been provided to us with the Parent’s consent. If you are a Parent and discover that your Child has provided us with Personal Information without your consent, please contact us at privacy@Cerebellumacademy.com. We will take steps to remove such information from our servers if we become aware that we have collected it without Parental consent. If you or your Child experiences any form of abuse or harassment while using our Services, please contact us at legal@Cerebellumacademy.com so that we may take appropriate action.
CONTROLLERS Cerebellum Academy is responsible for controlling the Personal Information it collects and processes when the Platform is used and Services are provided through it. The types of Personal Information we collect in this context are described in detail below.
PERSONAL INFORMATION The term “Personal Information” refers to information that can identify a User, such as first and last name, identification number, email address, age, gender, location, photograph, phone number, and any other information categorized as “personal data” under Data Protection Laws. “Sensitive Personal Information” includes passwords and financial data (excluding the last four digits of credit/debit cards), health data, official identifier, information about sexual life, sexual identifier, race, ethnicity, political or religious belief or affiliation, account details and passwords, or any other data/information categorized as “sensitive personal data” or “special categories of data” under applicable Data Protection Laws, and as used in this Policy. The term “Personal Information” as used in this Policy includes “Sensitive Personal Information” as may be applicable to the context of its usage. We advise against sharing any Personal Information with Cerebellum Academy unless specifically requested by us. In case you provide any Personal Information to Cerebellum Academy without us having specifically requested for it, we shall not be held liable for such information.
INFORMATION WE COLLECT Our collection of your information is based on specific reasons, such as providing Services on the Platform, communicating with you, and improving our Services. We gather this information from various sources including: 1. Information we collect directly from you: A. Basic account information: To access certain Platform features, you must create an account with us and provide basic information such as your name, email address, state/country of residence, password, username, and phone number. B. Know Your Customer (KYC) information: If you are a registered Content Provider, we also collect KYC information, including your PAN number, Aadhaar number, driver’s license, passport, entity details, list of directors/partners, social security number, and relevant documents. We collect this information to complete our verification process as required by agreements executed with you. C. Public profile information: For Content Providers, we may collect additional information to create a public profile on the Platform, which includes your username, brief description of your content, educational qualifications, past associations, and photo. Your KYC information is not shared on public profiles. D. Information from communication with us: When you communicate with us through email, phone, or other means, we may store your correspondence, email address, and phone number. We also track your browsing behavior on our Platform for statistical purposes and collect any Personal Information you provide in surveys, contests, events, webinars, or other forms of communication with us. 2. Information we collect automatically: A. Device and log information: We collect information typically made available by web browsers, servers, and mobile devices, such as browser type, IP address, unique device identifiers, language preference, referring site, date and time of access, operating system, and mobile network information. We also collect log information when you make changes to your account information on the Platform. B. Usage information: We collect information about how you use our Platform, including page views, support document searches, features enabled for your account, and interactions with other parts of our Services. We also gather information about your Supported Device, such as screen size, cellular network name, and mobile device manufacturer. C. Location information: We may determine your approximate location based on your IP address to improve our Platform Services. D. Information from cookies and other technologies: We may collect information about you through cookies and similar technologies stored on your device. For more information on our use of cookies, please refer to our Cookies Policy. 3. Information we collect from other sources: We may receive information about you from other sources, such as social media sites or Google services, if you connect to our Services through those sites. We may combine this information with other data we collect about you.
BASIS FOR COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION: 1. Collection Basis: We gather and handle your Personal Information based on legal parameters that depend on the nature of the information and the reasons for processing it, which include: A. Consent: We obtain your consent to process certain Personal Information, as required by applicable Data Protection Laws, and will only perform such processing where we have secured your consent at the time of collection. B. Compliance with a legal obligation: We may process your Personal Information to the extent necessary to comply with a legal obligation. 2. Personal Information Processing: We may process your Personal Information for the purposes and uses outlined in this Policy, based on one or more of the following legal grounds: A. Necessity to perform the Services you have requested or to comply with your instructions or other contractual obligations between you and us; B. Compliance with our legal obligations and records of compliance processes. C. Legitimate interests of us or a third-party recipient of your Personal Information, provided that those interests do not override your interests or fundamental rights and freedoms; D. Your choice to publish or display your Personal Information in a public area of the Platform, such as a comment area; E. Necessity to protect your vital interests. F. Necessity in the public interest; or G. Your express consent to process your Personal Information in a particular manner. We do not use Personal Information for making any automated decisions or creating profiles other than what is described in this Policy. If the processing of your Personal Information is based on your consent, you have the right to withdraw it at any time. Please note that withdrawing your consent may result in us being unable to continue offering our Services to you, and we reserve the right to withdraw or cease from offering our Services upon your consent withdrawal. To withdraw consent, you may contact us with a written request using the contact details provided in the ‘Privacy Grievances’ section below. Upon receipt of your request to withdraw your consent, we will communicate the consequences of withdrawal and process your request upon your agreement.
HOW WE USE AND SHARE THE INFORMATION COLLECTED
  1. We utilize and handle your information in the following ways:
  1. Providing Services on our Platform: We collect and use your information to grant you access to our Platform and its Services. This includes managing your account, providing customer support, facilitating transactions, verifying user details, and resolving any technical issues that may arise. Our legal basis for processing your data in this manner is either your consent or our legitimate interest in administering our Platform and fulfilling our contractual obligations with you.
  2. Improving our Platform and Ensuring Safety: We use your information to enhance and tailor our Platform and Services, such as through automatic updates and analyzing usage patterns to create new features. Additionally, we employ your data to prevent, investigate, and mitigate criminal activity, fraud, and other potential security breaches that could harm Cerebellum Academy or our users. Our legal basis for these processing activities is either your consent or our legitimate interest in safeguarding our Platform and network.
  3. Marketing and Communication: We may use your information to create targeted marketing campaigns and communicate with you about our offerings, solicit feedback, and introduce new products and services. Our legal basis for processing your data in this manner is either your consent or our legitimate interest in promoting our Platform and maintaining customer relationships.
  4. Legal Claims and Risk Management: We may use your Personal Information to establish, exercise, or defend legal claims, manage risks, or obtain professional advice. Our legal basis for these processing activities is our legitimate interest in protecting our business, Platform, and legal rights.
  5. User Analytics: We may gather information to better understand how our users utilize and interact with our Services. This data helps us identify areas of our Platform that require improvement and enhance our offerings to better meet the needs of our customers.
In instances where we use your information for any other purposes not mentioned here, we will obtain your consent or act in accordance with your directives.
2. We will only share the information collected according to the terms of this Policy as specified below. We do not sell or give away any Personal Information collected from you for monetary or other benefits. Only authorized representatives of Cerebellum Academy who have a need to know will use the information obtained from you and with your consent. If there is any unauthorized use or disclosure of information or if you file a complaint as stated in the ‘Privacy Grievances’ section below, we will investigate such complaints and take necessary actions as per the applicable Data Protection Laws. Affiliates and Subsidiaries: We may share your information with our affiliates, subsidiaries, and other businesses under the same control and ownership, and their respective officers, directors, employees, accountants, attorneys, or agents, who require the information to help us provide Services or process the information on our behalf. We require these entities to follow this Privacy Policy for any Personal Information shared with them. If you have availed any Service offered by Cerebellum Academy in collaboration with one or more Group Platforms, we may share your Personal Information with the relevant Group Platform, who may communicate with you regarding other products/services offered by them separately via email, phone, SMS, or other modes of communication. You can always choose to opt-out of receiving such promotional communications from a Group Platform through the unsubscribe link in the email or other options communicated to you. Third-party vendors/service providers, including integrated services on the Platform: We may share information about you with third-party vendors or service providers (including consultants, payment processors, and other service providers and integrated services) who require the information to provide their support services to us or you or to provide their services to you on our behalf either directly or through the Platform. These services may include providing customer support, performing business and sales analysis, supporting website functionality, facilitating payment processing, and supporting contests, surveys, and other features offered on our Platform. Such third-party vendors are not allowed to use the information for any purpose other than what it was provided for, and they are required to process and use the information in accordance with this Privacy Policy. Third-party platforms to facilitate additional offerings: We may share information about you with third-party platforms that are used to create interactive forums between Content Providers and Learners to provide a better learning environment. The information shared with these platforms is limited to the information required to facilitate your participation in the forums and is based on your consent through the Platform or otherwise. However, the privacy practices of these platforms are independent of this Policy, and we recommend that you read through the privacy policies and terms and conditions of the relevant platforms prior to consenting to be a part of any forums made available on these third-party platforms. Legal Disclosures: We may disclose information about you in response to a court order or other governmental request. We reserve the right to disclose such information if we believe in good faith that it is necessary to comply with applicable laws, regulations, court orders, government and law enforcement agencies’ requests, protect and defend Cerebellum Academy’s or a third party’s rights and property or the safety of Cerebellum Academy, our users, our employees, or others, or prevent, detect, investigate, and take measures against criminal activity, fraud, and misuse or unauthorized use of our Platform and/or to enforce our Terms and Conditions or other agreements or policies. We only share the information collected in accordance with our Policy and do not sell or reveal your Personal Information for any valuable consideration. Authorized representatives of Cerebellum Academy may use your information on a need-to-know basis and as per your consent. If there is any unauthorized use or disclosure of information, we will investigate and take appropriate action as per applicable Data Protection Laws or in response to your complaint filed under the ‘Privacy Grievances’ section. In some cases, we may share information about you with our affiliates, subsidiaries, and other businesses under the same control and ownership, who need the information to help us provide the Services or process the information on our behalf. We require them to follow this Privacy Policy for any Personal Information shared with them. We may also share your Personal Information with a relevant Group Platform if you have availed any Service that is offered by Cerebellum Academy in collaboration with them. You will have the option to opt out of receiving promotional communications from a Group Platform. We may share information about you with third-party vendors or service providers who need the information to provide their support services to us or you, or to provide their services to you on our behalf. Such vendors are required to process and use the information in accordance with this Privacy Policy. We may also share information about you with third-party platforms that are used to create interactive forums between Content Providers and Learners. The information shared with these platforms is limited to what is required to facilitate your participation in the forums, based on your consent through the Platform or otherwise. If Cerebellum Academy undergoes a merger, acquisition, sale of assets, or bankruptcy, user information may be transferred or acquired by a third party, but this Privacy Policy would still apply. We may share usage data with third-party advertisers, advertisement networks, and analytics providers through cookies and similar technologies. We may also share and disclose information with your consent or at your direction. If we share information for reasons not described in this Policy, we will seek your consent or share information upon your direction.
CROSS-BORDER DATA TRANSFER When you use our Platform, your information, including Personal Information, is stored, processed, and transferred to servers and databases located in Singapore, India, and the USA, which are operated by Amazon Web Services (AWS). We may also store, process, and transfer information in and to servers located in other countries, depending on where our affiliates and service providers are located. Please be aware that these countries may have different privacy laws that may not be as strict as the ones in your country. As a result, your Personal Information may be subject to disclosure to governmental bodies, regulatory agencies, or other private entities, in response to applicable legal requirements, such as a court order or a regulatory inquiry. If you use our Platform from outside India, such as in the USA, EU, EEA, or UK, your information may be transferred, stored, and processed in India. By using our Platform or providing us with your information, you consent to the transfer of your information to India and other countries outside your country of residence. If you are located in the EU and are subject to applicable data protection laws, we process your information based on legal grounds to perform our contract(s) with you, to comply with our legal obligations, and for our legitimate business purposes, such as improving our operation and Services and preventing fraud. We rely on legal bases to transfer information outside the EU, EEA, and UK, and we ensure that any Personal Information that we transfer is protected in compliance with applicable Data Protection Laws and regulations.
DURATION FOR WHICH YOUR INFORMATION IS STORED ON THE PLATFORM In most cases, when you delete information or your account from our Platform, it will be removed from our servers as well. However, we may need to keep some of your information for a certain period of time to comply with legal obligations or business requirements as stated above. Please note that we may not be able to delete all communications, photos, files, or documents that you have made publicly available on the Platform (such as comments or feedback). However, we will anonymize your Personal Information so that it can no longer be associated with you as an individual. We will never disclose aggregated or de-identified information in a way that could identify you. If you want to exercise your rights to access, modify, or delete any of the information we have stored about you, please use the options available on the Platform. You can also contact us at privacy@Cerebellumacademy.com if you need any further clarification.
YOUR CHOICES  1. Choose the information you provide: You have the freedom to select the information you wish to provide to us, and the option to update or delete it. However, please keep in mind that certain information may be necessary for accessing the Platform or its features, and not providing it may limit your access. 2. Manage your communications: You can also choose the type of communication you wish to receive from us, and whether you wish to receive any at all. Nonetheless, there may be some communications that are required for legal or security reasons, such as updates to various legal agreements, which you may not be able to opt out of. 3. Opt-out of Cookies and similar technologies: If you desire, you can reject or remove cookies from your web browser by changing the default settings. However, please note that certain services on the Platform may not be available or function properly if cookies are rejected, removed, or disabled.
YOUR RIGHTS In general, all users are entitled to the rights mentioned in this section. However, depending on your location, you may have specific rights regarding your Personal Information under the laws of your country. To understand your rights, please refer to the Country Specific Additional Terms provided below. As a user, you can exercise any of these rights by using the options available to you within the Platform upon logging in. If you encounter any issues or require clarifications, you can always contact us at the address specified in the ‘Grievances’ section below, and we will address your concerns as required by applicable law. 1. Right to Confirmation and Access: You have the right to confirm and access your Personal Information, as well as any other supporting information that we have. 2. Right to Correction: You have the right to request the correction of your Personal Information that you believe to be inaccurate. You also have the right to request updates to your Personal Information that you believe to be incomplete or outdated.(except for your registered contact no and registered e-mail id) 3. Right to be Forgotten: You have the right to restrict or prevent the continuing disclosure of your Personal Information under certain circumstances. 4. Right to Erasure: If you wish to remove your Personal Information from our Platform, you have the right to request erasure of your Personal Information from our Platform. Please note that such erasure will permanently delete all your Personal Information from our Platform (except as specifically stated in this Policy), and your account may be deleted permanently and irretrievably. Please note that you can only exercise your rights with respect to your information, including Personal Information, and not that of other users. Additionally, when we receive any requests or queries over email or physically to the address specified in the ‘Grievances’ section below, we may need to ask you for additional information to verify your identity in association with the Platform and the request received, as per applicable Data Protection Laws.
INFORMATION SECURITY A. To protect the security of your information during transmission, we use Transport Layer Security (TLS) or Secure Sockets Layer (SSL) software (depending on your browser/supported device) that encrypts information you input. We also maintain the security of your information as required by applicable laws. B. We have electronic and procedural safeguards in place to collect, store, and disclose Personal Information (including Sensitive Personal Information). Our security procedures may require proof of identity before we disclose Personal Information to you. C. However, no method of data storage or transmission system is fully secure, and we cannot guarantee the absolute security of such systems against unauthorized access, disclosure, or destruction of your information in the event of a security breach. D. It is important for you to protect your account against unauthorized access to your password and your computer. If you suspect that your password has become known to anyone else or is being used in an unauthorized manner, you must change your password immediately or inform us to prevent such access. Sign out when you finish using a shared computer. E. All KYC information collected according to this Policy is fully encrypted and can only be accessed by designated authorities at Cerebellum Academy F. We take appropriate measures to ensure that third-party service providers providing services to us under appropriate contracts also take appropriate security measures to protect Personal Information in line with our policies.
PROMOTIONAL COMMUNICATIONS If you wish to stop receiving our promotional communications, you can opt-out of them using the provided setting within the Platform upon your login, by clicking the unsubscribe link in any email communication you receive from us or by sending an email to help@Cerebellumacademy.com. However, even if you opt-out of promotional communications, you may still receive transactional communications, such as service announcements, administrative and legal notices, and information about your account. If you want to delete your account or stop receiving any communications from us (except those legally required), you can do so using the enabled option within the Platform or by contacting us at privacy@Cerebellumacademy.com. It’s important to note that opting out of promotional emails will only affect future communications. If we have already shared your information with a third party (as mentioned in this Policy) before you changed your preferences or updated your information, you may have to change your preferences directly with that third party. We do not sell your Personal Information to third parties, and we never use your name or the name of your company in our marketing statements without your consent.
INTEREST-BASED ADS Cerebellum Academy may show interest-based advertising on external websites using information that you provide when you interact with our Platform and Services. Interest-based ads, also known as personalized or targeted ads, are displayed based on information obtained from your activities such as registering with our Platform or visiting sites that contain Cerebellum Academy content or ads. We comply with applicable laws, as well as self-regulatory principles and guidelines for online behavioral advertising established by the Advertising Standards Council of India, the Digital Advertising Alliance, and the Federal Trade Commission in relation to digital advertising. We do not share your Personal Information with advertisers or third-party websites that display our interest-based ads. However, advertisers and third-party service providers may assume that users who click on or interact with personalized ads are part of the intended audience. In addition, third-party sources may provide us with information about you, such as demographic data or the sites where you have been shown ads, which we may use to deliver more relevant and useful advertising. Advertisers or ad-serving companies may use technology to serve ads directly to your browser when you visit our sites. They receive your IP address automatically and may use cookies to personalize ad content and measure the effectiveness of their ads. We do not have control over the use of cookies or other features by advertisers or third-party sites, and their privacy practices are not governed by our Policy. For more information, please contact them directly.
MODIFICATION TO PRIVACY POLICY As our business evolves, we may update this Policy periodically. We may choose to send occasional reminders of our notices and terms via email, unless you have opted out, but we recommend checking our Platform regularly to stay informed of any updates. Unless otherwise indicated, the current version of our Policy applies to all information we have about you and your account. We value the commitments we make and will not make significant changes to our policies and practices that would reduce the level of protection for customer information collected in the past without your explicit consent.
PRIVACY GRIEVANCES If you have any inquiries about this Policy, would like to exercise your rights, or have any concerns related to the privacy of your data or any privacy-related complaints, please submit a detailed description of your complaint by email to privacy@Cerebellumacademy.com
TERMS APPLICABLE IF YOU ARE AN INDIAN RESIDENT If you are a resident of India, you may be entitled to certain rights under the Personal Data Protection Bill (PDPB) once it becomes law. You can make any requests related to these rights through the option provided to you on our Platform after you log in. Alternatively, you can write to us as outlined in the “Privacy Grievances” section above, and we will address your concerns to the extent required by law. Here are your rights as an Indian resident under the PDPB:
  1. Right to Confirmation and Access: You have the right to confirm whether we are processing your Personal Information and to access the information we have about you along with supporting details.
  2. Right to Correction: You can ask us to rectify any Personal Information that you believe is inaccurate or incomplete.
  3. Right to Data Portability: Under certain circumstances, you can request that we transfer your Personal Information to another organization or to you.
  4. Right to be Forgotten: You have the right to restrict or prevent the disclosure of your Personal Information under certain circumstances.
  5. Right to Erasure: You have the right to request the erasure of your Personal Information from our Platform. However, please note that this will permanently delete your account from our Platform (except as specified in this Policy) and it may not be retrievable.
TERMS APPLICABLE IF YOU ARE A RESIDENT OF UNITED KINGDOM (UK), A EUROPEAN UNION (EU) COUNTRY OR EUROPEAN ECONOMIC AREA (EEA) If you are a resident of the United Kingdom (UK), European Union (EU), or European Economic Area (EEA), you have certain rights under the UK and EU General Data Protection Regulation (GDPR), which we will fulfill to the extent required by applicable law. You can exercise these rights by contacting us at the address provided in the “Privacy Grievances” section above. The following are your rights: 1. Right to access your Personal Information: You have the right to confirm whether we are processing your Personal Information and, if so, to access that information. 2. Right to rectification: If you believe that your Personal Information is inaccurate or incomplete, you may request that we rectify it. 3. Right to erasure: In some cases, you may request that we erase your Personal Information. 4. Right to object to processing: You may object to our processing of your Personal Information under certain conditions. 5. Right to restrict processing: You may request that we restrict the processing of your Personal Information under certain conditions. 6. Right to data portability: You may request that we transfer your Personal Information to another organization or directly to you, under certain conditions. 7. Right to make a complaint to a government supervisory authority: You may contact us if you believe that we have not processed your Personal Information in accordance with GDPR provisions. You may also file a complaint with the relevant Supervisory Authority or seek a remedy through the courts. 8. Right to not be subject to automated decision-making, including profiling: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces significant legal effects. We only collect and process your Personal Information where we have a legal rationale to do so, which depends on the type of Personal Information collected and the Services involved. Top of Form Regenerate response
TERMS APPLICABLE IF YOU ARE A CALIFORNIA STATE RESIDENT If you reside in the state of California, you are entitled to certain rights under the California Consumer Privacy Act (CCPA). These rights include: 1. The right to request access to the Personal Information that we have collected about you; 2. The right to know what Personal Information we plan to collect before we do so; 3. The right to opt in or opt out of marketing, analytics, and similar activities. 4. The right to receive equal services without discrimination; and 5. The right to request the deletion of your Personal Information. Details on how to exercise these rights, the types of information we collect, and how we collect it are outlined below. 1. CCPA NOTICE AT COLLECTION: When collecting information from you, we collect certain categories of Personal Information as described below, in accordance with the CCPA: A. Identifiers: This may include your name, email address, mobile number, username, unique personal identifier, and Internet Protocol (IP) address. We use Identifiers as described in the “How We Use and Share the Information Collected” section of this Policy, which may include your name, contact information, and device and online identifiers. B. Characteristics of Personal Information described in the California Customer Records statute: This may include your name, email address, username, unique personal identifier, and gender. We use Categories of Personal Information described in the California Consumer Records statute as set forth in the ‘How We Use and Share the Information Collected’ section of this Policy. C. Internet or other electronic network activity information: We collect cookies as described in our Cookies Policy and may automatically receive information from your browser and device such as the date and time of your visit to the Platform, your location, Internet Protocol (IP) address, domain server, browser type, access time, and data about which pages you visit on the Platform. We use Internet or other electronic network activity information as described in the “How We Use and Share the Information Collected” section of this Policy. D. Geolocation data: This may include your IP address, which we use as described in the “How We Use and Share the Information Collected” section of this Policy to determine your location. E. Audio, electronic, visual, or similar information: This may include your profile picture or other audio, or visual information uploaded as content to the Platform, which we use as described in the “How We Use and Share the Information Collected” section of this Policy. F. Inferences: We may make inferences based on the Personal Information collected, such as the likelihood of retention or attrition. We use inference information as described in the “How We Use and Share the Information Collected” section of this Policy. 2. CCPA DATA PRACTICES DURING THE LAST 12 MONTHS: A. Personal Information collected: We have collected the following categories of Personal Information in the past 12 months, as stated in this Policy:
  1. Identifiers
  2. Characteristics of Personal Information described in the California Customer Records statute
  3. Internet or other electronic network activity information
  4. Geolocation data
  5. Commercial information
  6. Audio, electronic, visual, thermal, olfactory, or similar information
  7. Inferences
B. Categories of sources: The Personal Information mentioned in this Policy has been obtained from both you and our payment processors. C. Business and commercial purposes for collecting:The categories of Personal Information mentioned above have been collected by us for the following reasons:
    1. To operate the Platform.
    2. To provide Services to you.
    3. To comply with our Terms and Conditions and contracts.
    4. To ensure the privacy and security of our Platform and Services.
    5. To manage our relationships with you.
    6. To communicate with you.
    7. To analyze the use of the Platform and our Services.
    8. To enhance your experience.
    9. To track visits to the Platform.
    10. To provide you with a more personal and interactive experience on the Platform.
    11. For usage analytics purposes.
D. Personal Information sold: In the previous 12 months, we did not engage in the sale of any categories of Personal Information.
    1. During the preceding 12 months, we have disclosed the following categories of Personal Information for a business purpose:
    2. Identifiers
    3. Characteristics of Personal Information described in the California Customer Records statute.
    4. Internet or other electronic network activity information
    5. Geolocation data
    6. Commercial information
    7. Audio, electronic, visual, thermal, olfactory, or similar information
    8. Inferences
Each of the above-listed categories of Personal Information has been shared with the following types of third parties: (1) corporate parents, subsidiaries, and affiliates; (2) advisors such as accountants and attorneys; (3) service providers including those for data analytics, data storage, mailing, marketing, website and platform administration, and technical support; and (4) operating systems and platforms. 3. CONSUMER RIGHTS AND REQUESTS UNDER THE CCPA Consumers have the right under CCPA to request that we disclose the Personal Information we collect, use, disclose, and sell, as well as request the deletion of certain Personal Information we have collected or maintained. You can make these requests to us as per the instructions provided below, and we will honor these rights where applicable. If a request is not submitted through one of the designated methods or is deficient in some way unrelated to our verification process, we will either treat it as if it had been submitted properly, or we will provide you with specific guidance on how to submit the request correctly or address any deficiencies with the request, as appropriate. A. Request to Know: As a California resident, you have certain rights under the CCPA. These rights include the right to request information about your Personal Information collected by us, including the specific pieces of information, categories of information, sources, third-party disclosures, and the business purposes for collection, disclosure, or sale. B. Request to Delete: You also have the right to request the deletion of your Personal Information, subject to certain exemptions under the law. Our response to such requests will cover the preceding 12-month period, and we will direct our service providers to delete your Personal Information from their records as well. Please note that we may not be able to honor a deletion request if an exemption applies. C. Submitting a Request: 1. Submission of Instructions: You can make a request for information or deletion by emailing privacy@Cerebellumacademy.com. In the case of deletion requests, we may provide you with the option to delete specific portions of your Personal Information, but we will also prominently present the option to delete all of your Personal Information. 2. Verification Process: To comply with legal requirements, we must verify the identity of individuals who submit requests to know or delete Personal Information. We will confirm that the person making the request is the consumer whose information we have collected by comparing the identifying information provided in the request with the Personal Information we have on record. As part of this process, you will need to provide your name, email address, and mobile number (if provided by you during registration or use of the Platform). We will notify you if we are unable to verify your identity. Please note-
  1. If we are unable to verify the identity of the requester for categories of Personal Information, we may refuse the request. In such cases, we will provide a copy of our Privacy Policy to the requester or direct them to it.
  2. If we are unable to verify the identity of the requester for specific pieces of Personal Information, we are not authorized to disclose such information. However, if the request is denied for this reason, we will consider it as a request for the disclosure of categories of Personal Information about the consumer.
  3. If we are unable to verify the identity of the requester for a deletion request, we may deny the request. If we determine that there is no reasonable method to verify the identity of the requester with the required level of certainty, we will explain the reason for our inability to verify and state it in our response.
3. Authorized Agents: If you choose to use an authorized agent to submit a request to know or delete your Personal Information on your behalf, you may do so through the methods specified in this Policy. However, we may ask you to fulfill the following requirements: (1) give your authorized agent written authorization to act on your behalf; (2) verify your identity directly with us; and (3) confirm directly with us that you have given your authorized agent permission to submit the request. These requirements may not be necessary if you have given your authorized agent power of attorney according to the California Probate Code. 4. Excessive Requests: If a User’s request is deemed manifestly unfounded or excessive due to its repetitive nature, we have the option to either (1) charge a reasonable fee or (2) decline the request and explain to the User the reason for the refusal. If we decide to charge a fee, it will be based on the administrative costs associated with providing the requested information or action. 5. CCPA Non-Discrimination: We acknowledge and respect your right to not be subjected to discriminatory treatment by us as a result of exercising your CCPA rights. We do not engage in any financial incentive or offer any price or service differences, nor do we discriminate against our Users or consumers who exercise their CCPA rights.