Rouxbe Video Technologies, Inc. Privacy Policy

Effective date: September 6, 2022

Sections

This Privacy Policy describes how we, Rouxbe Video Technologies, Inc., including our affiliates and subsidiaries (referred to as " we" "our" or "us"), collect, use, and share your personal information. This Privacy Policy applies to information that we collect when you visit our website "rouxbe.com", interact with the website features, sign up for our courses, or when you interact with us through our email, advertising, or Social Media campaigns (collectively, our "Services"). By accessing or using our Services, you agree to this Privacy Policy. This Privacy Policy may change from time to time, please see Changes to this Privacy Policy below for more information.

This Privacy Policy does not apply to employees or job applicants. Our Services are not intended for children under the age of 16. We do not knowingly collect personal information from children under 16. If we learn that we have collected personal information from individuals under the age of 16, we will delete that information.

Additional Privacy Rights

If you are a student who uses our Services through an educational institution, please see our Student Privacy Disclosure section. If you are a citizen of Switzerland, the United Kingdom, or a country in the European Economic Area, we explain the additional rights that you may have under European privacy laws in the European Privacy Rights section. If you are a resident of California, Nevada, or Virginia we explain additional rights that you may have in the U.S. Data Privacy Rights section.

Information We Collect

We may collect the following types of personal information in the following ways:

  • Information that you provide us when you register for a course, refer a friend, purchase gift cards, sign up for live events, fill out forms or questionnaires, respond to surveys, participate in a contest, provide comments or reviews, contact us, respond to our emails, contact support, fill out affiliate applications, or participate in our communities;
  • Information provided by our customers about course users, including name, email address, and site location or site location identifier (not precise geolocation);
  • Information that you provide when you create an account or use our Services, including name, address, e-mail address, physical address, telephone number, and demographic information (if requested);
  • Information that is collected automatically about your interaction with the Services through automatic tracking technologies (e.g., cookies, pixels, tags, or other tracking technology) that may or may not personally identify you (this information may be combined with information that does personally identify you). This includes information like IP address, device ID, advertising ID, Internet connection, network activity, operating system, browser type, session activity, clickstream data, referring or exiting URL, transaction details, type of device or equipment you use, course geolocation, your activity or interaction with our Services, the links you click on, whether you open our emails, or interactions with our Social Media accounts or marketing materials;
  • We may receive information from third parties such as affiliate marketing partners through our affiliate program if an affiliate partner links to our Services, the information we receive from the affiliate partner includes unique identifiers and information about the link that you clicked;
  • We may receive information from third party service providers, like survey tools, payment processors, support ticketing systems, affiliate program tools, refer a friend tools, or other service providers. They may provide us with the information that you provide through the applicable third party service provider tool, such as name, email address, or other information. They may also provide us with information about your interaction with the third party service provider’s tools or services through automated tracking technologies;
  • We may receive information from third party partners such as marketing partners or sponsors. These partners may share personally identifiable information with us such as name, email address, physical address, and phone number; and
  • We may use the information we collect about you to derive inferences. For example, we may derive inferences from your course registration history or activity within a course to provide recommendations about other courses that may be of interest to you.

Cookies & Automatic Tracking Technologies

Like many websites and online services, we use cookies, pixels, and other automatic tracking technologies to collect information about your use of our Services. Cookies are alphanumeric identifiers in the form of data files that are inserted and stored by your web browser on your computer’s hard drive.

Through cookies or similar tracking technologies, we collect usage information like your interactions with our Services. We associate this information with your IP address or other ID (e.g, device ID, unique identifiers, advertising IDs). Through automated tracking technology, we collect browser type and setting, time/date, language preferences, and device information, crash data, usage information, transaction information, links clicked, pages or content viewed, emails opened, and other similar kinds of information.

You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being set.

Social Media

Through our Services, we may provide you with access to social media pages, communications, websites, communities, or groups within social media sites ("Social Media"). When you interact with us through Social Media, you will be sharing your information (which will include personal information if you elect to share such information) with those Social Media platforms and any other individuals with access to the Social Media platform, community, or group. As with other third-party websites, the information that you share with the Social Media platforms will be governed by the privacy policies and terms of service of the providers the Social Media platform and not by the policies and procedures we describe here.

How We Use The Information We Collect

We use the personal information that we collect or receive:

  • To provide the Services and its contents to you and to our customers, to allow you to participate in the interactive features of the Services, and to support the Services;
  • To provide you with recommendations, to tailor or customize the Services to your profile, or to provide you with a custom experience;
  • To communicate with you about the Services or your account within the Services;
  • For research and development purposes, including to develop new products, services or features;
  • To analyze the Services, and to estimate audience size or usage;
  • To remember your preferences;
  • To validate information about you;
  • To provide and administer our affiliate purchasing programs;
  • To provide you with information, products, or services that you request, or that we think may be of interest to you;
  • To serve advertisements to you that may be of interest to you;
  • To administer contests and sweepstakes, communicate with entrants, notify winners, award prizes, and comply with applicable law;
  • To fulfill any other purpose for which you provided it;
  • To carry out our legal obligations and to enforce our rights, including collections;
  • To investigate misuse or misconduct relating to the Services;
  • To help protect you, our service providers or partners, or others from fraud, malicious activity, or other privacy or security-related concerns; and
  • In ways that we disclose to you when we collect the information, or for other notified purposes with your consent or at your direction.

How We Share Your Personal Information

We may share the personal information that we collect via the Services as follows:

  • With our service providers for business purposes;
  • With our customers if you enroll in a course that our customer makes available to you;
  • With your course instructors;
  • If you are a student, with your educational institution;
  • With third party partners like analytics providers (e.g., Google Tag Manager and Google Analytics) or Social Media for marketing and promotional purposes, such as ad placement;
  • With third party affiliates who participate in our affiliate programs to verify affiliate transactions;
  • With legal, accounting, and other professional service providers;
  • With legal authorities or third parties if we deem necessary to enforce our rights, or the rights of third parties (including in connection with your breach of this Privacy Policy or any other agreement between us);
  • When required by any applicable law, rule regulation, subpoena, or other legal process;
  • In connection with the negotiation or execution of a merger or sale of our business; or
  • To prevent illegal, harmful, fraudulent, or damaging activities.

Student Privacy Disclosure

If you are a student and register or use our Services through a course made available by your educational institution, you may have additional rights under the Family Educational Rights and Privacy Act (FERPA). As a service provider to educational institutions subject to FERPA, we are considered a "school official" under FERPA. That means that, while we are not required to seek consent to collect and process student personally identifiable information, we are prohibited from using or disclosing student personally identifiable information for any purpose other than to provide the Services to the educational institution.

Where we provide Services to educational institutions, we often obfuscate the personally identifiable information so that it is no longer identifiable. However, where we do collect personally identifiable information from students, we collect the following information:

  • First name, last name, and email address;
  • IP address and device ID, which are associated with information collected about the student’s interaction and activities while using the Services (for more information about what we collect automatically through tracking technology, please see the section Cookies & Automatic Tracking Technologies above). We do not use advertising cookies (e.g., Google Tag Manager or Facebook Pixel) on courses provided to educational institutions and their students;
  • Information submitted by a student in course feedback or information submitted by an instructor about the student’s course work;
  • For post-secondary students only, if you participate in a Social Media community or group, we will also receive information about your Social Media profile, your interaction with the Social Media group or community, including comments, likes, messages, etc.

Under FERPA, parents of students under 18 years of age have the right to access their child’s education records, the right to seek to have the records amended, and the right to have some control over the disclosure of personally identifiable information from the education records. When a student turns 18 or enters a postsecondary institution at any age, the rights under FERPA transfer from the parents to the student.

If you or your parent makes a record request under FERPA, we are required to use reasonable methods to authenticate the identity of the student or parent requesting the record, including requesting two types of personally identifiable information as verification.

European Data Resident Data Privacy

If you are a resident of Switzerland, the United Kingdom, or a country within the European Economic Area (EEA), you may have rights under European data protection laws regarding the processing of your personal information. You have the right to access the information that we hold about you and, in some cases, you may have the right to ask that your information be corrected, erased, or transferred (subject to limitations under applicable law). You may also have the right to object to or request that we restrict the processing of your personal information. If we collect information based on your consent, you have the right to revoke your consent.

If you would like to exercise any of these rights, you may contact us as indicated in the Contact Us section below. The rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of a third party. We may request specific information from you to confirm your identity. In some cases, we may charge a reasonable fee for access to your information.

Our lawful basis for collecting personally identifiable information is to fulfill contracts with you or with our customer, our legitimate interest in providing the Services and content to you, with your consent, or to comply with our legal obligations.

We will retain information for as long as necessary to fulfill our legitimate business purpose, to comply with any laws or regulations, resolve disputes, or enforce our agreements. We may retain information longer for our legitimate business interest if retention is not outweighed by your personal rights and freedoms.

Dispute Resolution

You may direct questions or complaints arising from this Privacy Policy to us by contacting us through the channels indicated in the Contact Us section below. Residents of the EEA and Switzerland may file a complaint with a data protection authority. The data protection authority will require you to first attempt to resolve any complaint with us, please see the Contact Us section below to file a complaint with us.

Any other disputes arising out of or related to this Privacy Policy will be handled in accordance with the dispute resolution process indicated in our Terms of Use.

U.S. States Data Privacy Rights

California Resident Privacy Rights

If you are a California resident, the California Consumer Protection Act (CCPA), as amended by the California Privacy Rights Act (CPRA), may provide you with additional rights regarding your personal information. The rights outlined in this section do not apply to information exempted under the CCPA, including aggregated data, or to individuals who are not residents of California.

CCPA Rights

To the extent provided under the CCPA, and subject to applicable exceptions, California residents have the following rights with respect to the information that we collect:

  • The right to know the categories and specific personal information we have collected, the categories and sources from which we collected the personal information, the categories of third parties with whom we share personal information, and the business or commercial purpose for collecting or selling (if applicable) personal information;
  • The right to request a copy of the personal information that we collected about you during the past 12 months;
  • The right to opt out of sales of personal information (if applicable) or sharing personal information for cross-contextual behavioral advertising (if applicable);
  • The right to request that we delete the personal information that we have collected from you, subject to certain exceptions;
  • The right to correct inaccurate information that we maintain about you;
  • The right to limit the disclosure of sensitive personal information, if we use or disclose sensitive personal information;
  • The right to request information about and opt out of automated decision making (if applicable); and
  • The right to exercise the rights described above free from discrimination or retaliation, as prohibited by the CCPA.

For purposes of CCPA, in the previous 12 months, we collected the following categories of personal information and share personal information with the following categories of third parties:

Information Examples Categories of Third Parties Shared
Identifiers Name, email address, unique identifier, online identifier, transaction identifiers, device ID, advertising ID, and IP address Customers
Service providers
Social Media
Affiliate partners
Third parties where you initiate a disclosure (such as refer a friend or where you purchase a gift card)
Select information in customer records Name, email, address, and telephone number. Our payment processors information is collected about the transactions you make (such as transaction date, payment information, credit card or debit card number and zip code) Customers
Service providers
Affiliate partners
Geolocation Course IP address, not precise location Service providers
Social Media
Commercial information Name, address, telephone number, products or services purchased or considered, and other purchasing or consuming histories Customers
Service providers
Affiliate partners
Internet or network activity such as browsing history, search history, and information regarding a consumer’s interaction with website, application, or advertisement Service providers
Education information such as information that is not publicly available as defined in the California Family Educational Rights and Privacy Act Customers that are educational institutions
Professional or employment related information Job applicant information Service providers
Characteristics of protected classifications under California or Federal law Job applicant information Service providers
Inferences from information that could be used to create a profile Such as course preferences Service providers

We have not collected the following categories of information in the previous 12 months:

  • Biometric information, such as hair color, eye color, fingerprints, retinal scans, or thermal, olfactory, or similar information;
  • Audio, electronic, and visual information; and
  • Sensitive personal information.

We disclose this information for the purposes described in How We Use the Information We Collect and How We Share Your Personal Information in the sections above.

We do not “sell” personal information as the term “sell” is traditionally understood. However, we use third party analytics and advertising tools on our website that place third party cookies. These third parties collect data for their own purposes, in addition to providing services to us, which may be considered a sale in California. California residents may opt-out of sharing of this information by opting out of advertising cookies through our cookie consent banner.

We do not collect information about user’s age. We do not provide programing directed at students under the age of 16. Therefore, we do not have actual knowledge of collection of information from individuals under the age of 16 and do not have actual knowledge of sales of information of individuals under the age of 16.

We do not collect sensitive personal information as that term is defined by the CCPA.

Virginia Resident Privacy Rights

If you are a Virginia resident, the Virginia Consumer Data Protection Act (VCDPA) may provide you with additional rights regarding your personal information. The rights outlined in this section do not apply to information exempted under the VCDPA, including aggregated data, or to individuals who are not residents of Virginia.

We describe the Information We Collect, How We Use the Information We Collect, and How We Share Your Personal Information in the sections above. We do not collect sensitive personal information as that term is defined by the VCDPA.

To the extent provided under the VCDPA, and subject to applicable exceptions, Virginia residents have the following rights with respect to the information that we collect:

  • The right to know the personal information that we process about you;
  • The right to access personal information that we process about you;
  • The right to correct inaccurate information that we maintain about you;
  • The right to obtain a copy of the personal information that we have collected about you;
  • The right to opt out of the processing of personal information for (i) targeted advertising; (ii) the sale of personal data; or (iii) profiling for decisions with legal or other significant effects on the consumer;
  • The right to request that we delete the personal information that we have collected from you, subject to certain exceptions; and
  • The right to exercise the rights described above free from discrimination or retaliation as prohibited by the VCDPA.
Financial Incentives

Financial incentives are programs, benefits, or other offerings, including payments to consumers as compensation, paid in exchange for the disclosure, deletion, or sale of personal information about them. We do not offer financial incentives to a consumer for the disclosure, deletion, or sale of their personal information. We offer individuals the ability to “refer a friend” in exchange for discounts, which includes the disclosure of the personal information regarding another consumer.

Exercising Your CCPA or VCDPA Rights

California residents may exercise their CCPA rights and Virginia residents may exercise their VCDPA rights by contacting us by phone or email as indicated in the Contact Us section below. Your rights may only be exercised by you or by your designated agent. You may only submit a CCPA request to know twice within a 12-month period.

Your request must include enough information to allow us to reasonably verify that you are the person about whom we collected personal information or an authorized representative, which may include: (1) verifying your account information if you have an account with us; or (2) requesting two forms of identification that are reliable for verification purposes, unless the request includes sensitive information and, in which case, we may require three forms of verification and a signed declaration. The information included in your request must allow us to properly understand, evaluate, and respond to it.

We cannot respond to your request if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. If we cannot verify your identity or authority, we will not fulfill your request. We will only use personal data provided in the request to verify the requestor’s identity or authority to make it.

You may submit a request through a designated agent. You must instruct that agent that they will need to state that they are acting on your behalf when making the request, have reasonably necessary documentation, and be prepared to provide the necessary personal information to identify you in our database.

California Shine the Light Disclosure

Under California Civil Code sections 1798.83- 1798.84, California residents are entitled to ask for a notice identifying the categories of personal customer data which we share with our affiliates and/or third parties for their own direct marketing purposes and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the address in the Contact Us section below.

Nevada Resident Privacy Rights

If you are a resident of Nevada, you have the right to opt out of the sale of certain information to third parties who intend to license or sell that information. If we sell your information, you can exercise this right by contacting us by submitting a communication as directed in the Contact Us section below. If the request is via email, please include the subject line "Nevada Do Not Sell Request" and providing us with your name and the email address.

Correction of Data and Data Retention

We retain personal information for as long as required to engage in the uses described in this Privacy Policy, unless a longer retention period is required by applicable law.

If you register to use our courses, you may correct or update your personal information by logging into the course and updating your information in the privacy settings tab. You may delete your personal information by deactivate your account. To deactivate your account, you may email our customer support at privacy@rouxbe.com or by delete your account within the course.

Security

We take security of your information seriously and take precautions, including technical, administrative, and physical measures, to safeguard your information collected through the Services. However, no method of online data transfer, processing or storage is 100% secure, and we do not guarantee the security of your personal information.

Links

The Services may contain links to third party sites and services. We do not endorse and are not responsible for the privacy practices or the content of these third party sites or services. We exercise no control over how your information is stored, maintained, or displayed by third parties or on third-party sites.

Your Choices

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising: You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Services may not be accessible or not function properly.
  • Promotional Offers. If you wish to opt-out of our promotional communications, you can opt-out by sending us an email stating your request to the email address identified in the Contact Us section below or by clicking “unsubscribe” in response to a promotional email. This opt out does not apply to communications about courses that you register for, transactions or purchases that you make, or other operational communications.
  • Targeted Advertising. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI's website.

Changes to this Privacy Policy

We may change this Privacy Policy at any time. If we change this Privacy Policy, we will notify you of the changes by posting them at rouxbe.com/privacy, at the login page for the Services, or by providing you with notice of the modification by email. We will indicate when such changes are effective by updating the effective date at the top of this Privacy Policy. By continuing to access or use the Services after we have posted a modification or have provided you with notice of a modification, you indicate your agreement to the modified Privacy Policy. If the modified Privacy Policy is not acceptable to you, please do not use the Services.

Contact Us

To contact us you may email us at privacy@rouxbe.com. You may also submit a request to the following address or call us at:

Mailing Address:
Rouxbe Video Technologies, Inc.
408-55 Water Street,Unit 8322
Vancouver, B.C.
V6B 1A1
Canada
Phone:
800-677-0131 (North America Toll-Free)

Change Log

September 6, 2022

Updated structure and format of privacy policy, included references to additional rights under U.S. or E.U. law which may be applicable to certain individuals, updated how information is collected, shared, and used.