Privacy Policy

The Kodorra website and service including (without limitation) www.kodorra.com (the “Site”) and other all websites, mobile applications and other interactive properties through which the service is delivered (collectively, the “Services”) are owned, operated and distributed by Kodorra, a Malaysian corporation (referred to in this Privacy Policy as “Kodorra” or “we” and through similar words such as “us,” “our,” etc.). By accessing any part of the Services, you are agreeing to the terms and conditions described below (this “Privacy Policy”) and the terms and conditions of our terms of service (the “Terms of Service”). If you do not agree to any of these terms, you should not use the Services. This Privacy Policy applies to all users, including both users who are simply viewing content available via the Services and users who have registered as members of Kodorra.

We may, at our sole discretion, modify this Privacy Policy at any time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. By accessing the Services at any time after such modifications, you are agreeing to be bound by the updated policy. This Privacy Policy was last modified as of August 14, 2018.

General

Your privacy is very important to us. Accordingly, we have developed this Privacy Policy in order for you to understand how we collect, use, communicate and disclose and make use of Personal Data (as defined below). The following outlines our privacy policy.

EU Personal Data

If you are located in the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined in the EU Privacy Notice below.

Personal Data

When your register with us and become a Kodorra Member, when you choose to teach or attend a course, we will ask you for Personal Data. “Personal Data” refers to information about you that can be used to contact or individually identify you. This includes, but is not limited to, your name, email address, but does not include your credit card number or billing information. Transactions on Kodorra involving your billing and payment information are processed by PayPal and Stripe and are subject to their privacy policies. We do not store any of the credit card or banking information that you provide to these payment processors.

We will not give your name, email, or other Personal Data to unaffiliated third parties except with your consent or as otherwise set forth in this privacy policy. Though we employ industry standard measures to preserve user privacy, we may need to disclose Personal Data when required by law or when we have a good faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process that we receive or to protect our interests or the safety of others. In addition, we may provide Personal Data to employees, consultants or other business or persons for the purpose of processing such information on our behalf. In such circumstances, we require that these parties agree to protect the confidentiality of such information and to comply with the terms of this Privacy Policy. We may use your Personal Data to operate, improve, understand and personalize our Services.

Voluntary Disclosure

Any Personal Data or content that you voluntarily disclose in public areas becomes publicly available and can be collected and used by other users for any reason. Your profile pages (“Profile”) and any online courses you participate in are typically publicly available.

Children’s Privacy

We do not knowingly collect or solicit Personal Data from anyone under the age of 16. If you are under 16, please do not attempt to register for the Services or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Data, please contact us.

Information About Cookies

We use your IP address to help diagnose problems with our server, to administer our Services, and to analyze traffic patterns on the Services. The Services also use cookies and similar technologies such as pixel tags, web beacons, clear GIFs, and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser and tell us how and when you visit and use our Site and Services, to analyze trends, learn about our user base and operate and improve our Services. We may also supplement the information we collect from you with information received from third parties.

Some Cookies are placed by a third party on your device and may provide information to us and third parties about your browsing habits (such as your visits to our Site or Services, the pages you have visited and the links and advertisements you have clicked). These Cookies can be used to determine whether certain third party services are being used, to identify your interests, to retarget advertisements to you and to serve advertisements to you that we or others believe are relevant to you. We do not control third party Cookies. To find our more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.

Third Party Advertising

We may serve advertisements, and also allow third party ad networks, including third party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Internet-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of Third Parties (but will not include your name, address, email address or telephone number). Such information may be gathered through tracking users’ activities across time and unaffiliated properties. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.

We do not share your Personal Data with advertisers without your consent. However, if you click on or otherwise interact with an advertisement there is a possibility that the advertiser may place a Cookie in your browser and note that it meets the criteria they selected.

Other Sites

The Services may contain links to other websites or services. We are not responsible for the privacy practices or the content of such websites or services, and you should review the privacy policy of each such website or service to make sure that you are comfortable with it before providing any Personal Data. We do not receive any of the credit card information you provide to our third party payment processors, and all such information is subject to their privacy policies.

Business Transfers

In the event that we are acquired by or merged with a third party entity, we reserve the right to transfer or assign the information we have collected from users, including without limitation Personal Data, as part of such merger, acquisition, sale, or other change of control. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how your Personal Data is treated, transferred, or used.

Transfers to the United States

The Services are hosted in the United States. If you are accessing the Services from the European Union, please see the section titled “Transfers of Personal Data” in the EU Privacy Notice below. If you are accessing the Services from any other region with laws or regulations governing personal data collection, use, and disclosure that differ from United States laws, please be advised that through your continued use of the Services, which is governed by United States law, this Privacy Policy, and our Terms of Service, you are transferring your Personal Data to the United States and you consent to that transfer.

EU Privacy Notice

If you are located in the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this EU Privacy Notice section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but, in addition to the information identified in the Privacy Policy as Personal Data above, “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Kodorra will be the controller of your Personal Data processed in connection with the Services.

If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us.

What Personal Data Do You Collect From Me?

We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services.

Information we collect directly from you: We receive Personal Data directly from you when you provide us with such Personal Data, including without limitation the following:

  • First and last name
  • Email address
  • Date of birth
  • Gender
  • Location information (limited to city, state, zip code, country, and time zone)
  • Links to your social media accounts
  • Any other information you choose to share publicly on the Services

Information We Receive From Third Party Sources

Some third parties such as our business partners and service providers provide us with Personal Data about you, such as the following:

  • Account information for third party services. If you interact with a third party service when using our Services, such as if you use a third party service to log-in to our Services (e.g., Facebook Connect), or if you share content from our Services through a third party social media service, the third party service will send us information about you, such as information from your public profile, if the third party service and your account settings allow such sharing. The information we receive will depend on the policies and your account settings with the third party service.
  • Information from our advertising partners. We receive information about you from some of our service providers who assist us with marketing or promotional services related to how you interact with our websites, applications, products, services, advertisements or communications.

Information We Automatically Collect

Some Personal Data is automatically collected when you use our Services, such as the following:

  • IP address
  • Your activity on the Services
  • Device identifiers
  • Web browser information
  • Page view statistics
  • Browsing history
  • Transaction information (e.g. transaction amount, date and time such transaction occurred)
  • Cookies and other tracking technologies (e.g. web beacons, pixel tags, SDKs, etc.).
  • Location information (e.g. IP address)
  • Log data (e.g. access times, hardware and software information)

Consent

In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.

Other Processing Grounds

From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

How and With Whom Do You Share My Data?

We share Personal Data with vendors, third party service providers and agents who work on our behalf and provide us with services related to the purposes described in this Privacy Policy or our Terms of Service. These parties include:

  • Payment processors
  • Fraud prevention service providers
  • Ad networks and marketing tools
  • Analytics service providers
  • Engineering and development tools
  • Staff and contract personnel
  • Hosting service providers

We also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include:

  • Social media services (if you interact with them through your use of the Services)
  • Third party business partners who you access through the Services

How Long Do You Retain My Personal Data?

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

What Security Measures Do You Use?

We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity.

What Rights Do I Have Regarding My Personal Data?

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please contact us.

  • Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access your Personal Data by contacting us.
  • Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by making changes to your Profile. You can request that we correct or supplement such data by contacting us.
  • Erasure: You can request that we erase some or all of your Personal Data from our systems by contacting us.
  • Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
  • Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
  • Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.

Transfers of Personal Data

By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Kodorra and you authorize Kodorra to transfer, store and process your information in Malaysia, the U.S., and possibly other countries.

What If I Have Questions?

If you have any questions about our privacy policy and our data practices generally, please contact us.