Last updated: February 1, 2021.
In this agreement, Adeption is used to represent the legal entities it is provided by: in the United States of America – KtoAct limited (US registered company); Rest of World – Adeption Limited (New Zealand registered company).
As used herein the term "use" shall mean use, access, install, sign into, connect with, download, visit or browse the Services.
By doing so Adeption is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). Furthermore, this allows for the possibility, under certain conditions, for You to invoke binding arbitration. Adeption takes responsibility and is liable for upholding the principles of Privacy Shield in the case of onward transfer of data to third parties.
This policy describes:
This policy applies only to information we collect in this App and in email, text, and other electronic communications sent through or in connection with Our Services.
This policy DOES NOT apply to information that:
Our other websites and apps, and these third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.
If You are provided access to Adeption by Your organization or employer that has entered into a Data Protection Agreement with Adeption, the terms of the Data Protection Agreement prevail, and this Privacy and Use of Data Policy does not apply to You.
Additionally, if Your organization or employer that has entered into a Commercial Agreement with Adeption that states that the terms of this Privacy and Use of Data Policy are replaced by another Policy, the terms of the other Policy prevail, and this Privacy and Use of Data Policy does not apply to You.
If you are unsure if your Organization or Employer has engaged in such Agreement, then it is recommended that contact your Organization or Employer, or if in doubt accept the terms of this Privacy and Use of Data Policy.
Table of Contents
Adeption may collect different information from or about You depending on the manner in which You use the Services. The following examples are provided to help You better understand the information We may collect through Your use of the Services.
Please note, Adeption is not responsible for how others use information that is publicly available or otherwise accessible to others who have access to the Services.
When You sign up for and use the Services (including through a Third Party Platform) We will collect any information You provide to Us directly such as the following:
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 information You provided to Us, such as e-mail address, password, Your phone number, and we will assign You a unique identifying number (“Registration Information”).
You may also have the option of providing additional information about Yourself, including but not limited to a photo, headline, website link, social media profiles, or other information you may choose to enter ("Profile Information") to create a profile ("Profile"). Your Profile and Profile Information will be publicly viewable to others.
Some of the Services may allow You to interact with other Users and/or post, share, communicate or otherwise transmit content publicly, such as by posting comments in a page, sending messages to others, or posting photos (collectively "Shared Content" or "Public Posting"). We may collect and store Public Postings and Shared Content. Shared Content or Public Postings may be publicly available or viewable by others depending on where such content is posted.
You hereby grant Adeption a non-exclusive right and license to reproduce, distribute, publicly perform, offer, market and otherwise use and exploit the Public Postings and Shared Content.
If You make any purchases through our Services, such as for Courses, We may collect certain information regarding Your purchase (such as Your name and zip code) as necessary to process Your order. 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 access, store or collect Your credit card information.
The Services may contain third party links or allow You to access the Services through Third Party Platforms, such as Facebook. If You use Our Services on or through a Third Party Platform, including via any any mobile and/or other Internet connected devices (“Wireless Devices”), or click on third party links, the collection, use, and disclosure of Your information and Your use of the Services will also be subject to the privacy policies and other terms of such third parties or Third Party Platforms. You should review such privacy policies, terms, and other agreements.
By way of example only, We may 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:
You may choose not to allow the Third Party Platform to provide Us with certain information about You, but You might not be able to use certain features of Our Services if You enable such restrictions.
When You access the Services, including browsing Our Courses, We collect certain information by automated means. This information may include without limitation: (a) technical information about Your computer or Wireless Device, such as Your IP address, device type, operating system type and version, unique device ID, browser, browser language, domain and other systems information, platform types (collectively, “Technical Information”); and (b) usage statistics about Your interaction with the Services, including Courses accessed, time spent on pages or the Services, pages visited, search queries, click data, portions of the Services used, date and time, and other information regarding Your use of the Services (collectively, “Usage Data”).
This Technical Information and Usage Data, which may be linked to Your information, is collected through the use of server log files and tracking technologies, including: web beacons, which are small objects that allow Us to measure the actions of visitors using the Services.
Geolocation Information: IP addresses received from Your browser or device may be used to determine Your approximate location, such as the city, state and/or country associated with an IP address.
We may also employ web beacons or other technology for a variety of reasons such as: (i) allowing Us to know if a certain page was visited or whether an e-mail was opened; (ii) allowing Us to advertise more efficiently by excluding our current Users from certain promotional messages or identifying the source of a new installation.
Adeption 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 at which You like Your videos to play.
Session State. We use session cookies to collect information about how You interact with Our Services, to help Us improve Our Services, 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.
Third parties with whom We partner to provide certain features on Our site may use Local Storage Objects, also known as Flash Cookies (LSOs) to collect and store information. Various browsers may offer their own management tools for removing LSOs. To manage LSOs provided by Adobe, please click here .
We may use third-party browser and mobile analytics services on our Service, including but not limited to Google Analytics, HotJar, Fabric and Intercom. These service providers use the sort of technology described above to help us analyze how users use the Services, including by noting the third-party website from which you arrive, how often You use the Services, the events that occur within the Service, usage data, performance data, and where the application was downloaded from.
The information collected will be disclosed to or collected directly by these service providers, and We use this information to improve the Services, to better understand the functionality of the Services on a computer or other device, and to provide information that may be of interest to You.
You have some choices concerning our use of these analytics. For instance, to prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.
While we do not currently use online advertising, We may use third-party advertising technologies that allow for the delivery of advertising about our Services on other websites You visit and other applications You use. The ads may be based on various factors such as the content of the page You are visiting, information You enter such as Your searches, demographic data, user-generated content, and other information we collect from You. These ads may be based on Your current activity or Your activity over time and across other websites and online services and may be tailored to Your interests.
We use third parties (e.g., ad networks and ad servers such as Google Analytics and others) to help deliver these tailored advertising on other websites and in mobile applications. These third parties may place cookies or other tracking technologies on Your computer, mobile phone, or other device to collect information about Your use of the Services as discussed above and may access these cookies or other tracking technologies on Your computer, mobile phone, or other device You use to access the Services in order to serve these tailored advertisement.
When using a mobile application you may also receive tailored in-application advertisements. Each operating system, iOS for Apple phones, Android for Android devices and Windows for Microsoft devices provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems in order to opt-out of tailored in-application advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact the applicable platform operator.
Please note that to the extent advertising technology is integrated into the Services, You may still receive advertisements on other websites and mobile applications even if You opt-out. In that case, the advertising will not be tailored to Your interests. Also, we do not control any of the above opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices You make using these mechanisms or the continued availability or accuracy of these mechanisms.
We recognize the privacy interests of children and We encourage parents and guardians to take an active role in their children's online activities and interests. Children under the age of 13, or 16 if such children resides in the European Economic Area, should not use or attempt to use Our Services. If We learn that We have collected personal information (as defined by applicable law) from a child under 13 or a child under 16 in the Europea Economic Area, We will take reasonable steps delete such information.
Parents who believe that Adeption might have collected personal information from a child under the age of 13 may submit a request to firstname.lastname@example.org and request that the information be removed.
Adeption aims to leverage learning insights from our vast User groups to provide You and other Users with relevant and real inspirations. This will benefit Your learning experience and that of other Users.
Adeption may use the information We collect through Your use of the Services to:
We do not share personal information with unaffiliated third parties, except as stated in this Privacy Statement, including as necessary for our legitimate professional and business needs, to carry out your requests, to market our services, as required or permitted by law or professional standards, or otherwise with your consent.
We may share Course Information, course, assignment, and quiz completion activity, and certain Registration Information and Profile Information with Instructors or teaching assistants of the Courses in which You enroll or for which You request information. If You communicate with an Instructor, such as by asking a question, that Instructor will be able to view Your name and email address.
We may share Your information with third party companies that perform services on Our behalf, including for payment processing, order fulfillment, data analysis, marketing services, advertising services (including but not limited to retargeted advertising), e-mail and hosting services, and customer services and support. An example of these third party companies includes, but is not limited to Stripe.
We may also share Your information with third party companies that we partner with to provide certain services to You in connection with the Services. Those partners’ collection and use of information is subject to their privacy policies and other terms. You should review such privacy policies, terms, and other agreements.
As mentioned above your Profile Information and learning content may be publicly viewable or viewable within a defined network, including to other Users (Refer to How We use the information We collect). In addition, if you ask a question to an Instructor, Coach or Teaching Assistant, information about you, such as your name, and email address may be publicly viewable by other Users.
As discussed above, We may use internal or third-party analytics such as Google Analytics, Hotjar, Fabric to help understand Your usage of our services and to improve our Service. We also may use data enrichment services such as Twilio, MailJet, and Intercom. We may provide Your contact information ,Registration Information, Technical Information, Usage Data, or de-identified data or to data enrichment services, which match such information with publicly available database information, including contact and social information from other sources, such as Your email address, gender, company, job title, photos, website URLs, social network handles and physical addresses. We use this combined information to communicate with You in a more effective and customized manner.
In the event that Adeption undergoes a business transition, such as a merger, acquisition, corporate divestiture or dissolution (including bankruptcy), or a sale of all or a portion of its assets, We may share, disclose or transfer all of Your information to the successor organization in such transition or during steps in contemplation of such activities (e.g., due diligence).
We may share information with Your consent.
We may disclose or use aggregate or de-identified information for any purpose. This includes the development of behavioral learning insights from the data generated on the Adeption platform. The aggregated data or de-identified information may be on-sold to third parties.
Adeption takes appropriate security measures to protect against unauthorized access to, or unauthorized alteration, disclosure or destruction of, data that You share and We collect and store. These measures vary based on the sensitivity of the data we collect and store. Unfortunately, however, no system can be 100% secured, and We cannot guarantee that communications between You and Adeption, the Services, or any information provided to Us in connection with the information We collect through the Services will be free from unauthorized access by third parties.
We have implemented measures designed to secure Your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information You provide to Us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted [using SSL technology].
Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of User information at any time. Your password is an important component of Our security system. As such, it is Your responsibility to protect it. Do not share Your password with any third parties. If Your password has been compromised for any reason, You should change it immediately and contact email@example.com with any concerns.
We will notify You of a Security Breach as soon as practicable, but no later than seventy-two (72) hours after We becomes aware of it. Immediately following Service our notification of a Security Breach, the parties shall coordinate with each other to investigate the Security Breach.
At Our own expense, We will take reasonable steps to/use best efforts to immediately contain and remedy any Security Breach and prevent any further Security Breach, including, but not limited to taking any and all action necessary to comply with applicable privacy rights, laws, regulations, and standards.
We agree to maintain and preserve all documents, records, and other data related to any Security Breach.
You can always choose not to provide certain information to Us but You may not be able to use certain features of the Services. If You do not wish to receive promotional communications from Us, You can opt-out by: (i) following the unsubscribe instructions provided in the promotional communication You receive; or (ii) managing Your e-mail preferences by signing into Your Account, clicking on the Account Settings link under the Your Profile button in the site header.
Please note that despite Your opt-out choice or indicated email preferences, We will still send You transactional and/or relationship messages regarding the Services, including, for example, administrative confirmations, order confirmation, important updates regarding the Services, and notices regarding our policies.
The browser You use may provide You with the ability to control cookies or other types of local data storage. Your Wireless Device may provide You with choices around how and whether location or other data is collected and shared. Adeption does not control these choices, or default settings, which are offered by makers of Your browser or mobile device operating system.
To prevent Google Analytics from using Your information for analytics, You may install the Google Analytics Opt-out Browser Add-on by clicking here.
You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link.
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.
If You have any questions about Your information, our use of this information, or Your rights when it comes to any of the foregoing, contact us at firstname.lastname@example.org.
You may access and update Your information that Adeption collects and maintains in the following ways:
You may update the information You provide directly to Adeption by logging into Your Account and updating Your Account information at any time. You may also submit any requests for access to Your personal data and other data You provide on Adeption to email@example.com or in writing to Attn Legal: KtoAct Limited. 1 Belvedere Drive Suite 200, Mill Valley, CA 94941. Please allow up to thirty (30) days for a response.
If You are a Participant, and wish to delete Your Participant Account, You may do so by contacting Us via email at firstname.lastname@example.org, and We will make commercially reasonable efforts to respond to Your request within 72 hours.
In the event your Your account being terminated or deleted upon Your request, We will remove any specific content You have added to Adeption with the exception of the situations that arise below.
Please be aware that even after Your Account is terminated or deleted some or all of Your information or aggregated data from Your information may still remain on Our servers and databases and may be 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; (d) incorporated into machine learning data in an unidentifiable format; or (e) posted on a Third Party Platform. 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 Adeption or other Adeption Users. Adeption is not able and/or obligated to remove any of Your information from a Third Party Platform.
Even after You delete Your Account or Your Account is terminated, we may retain Your information as long as we have a legitimate purpose to do so and in accordance with applicable law. This may also required to meet the statutory requirements of governing bodies, such as government taxation departments, who require history of financial transactions performed on the Adeption platform. The timeframe of how long this information is required by law to be stored may vary depending on the country in which the transaction was made. The type of information required by statutory bodies may also vary, however in most cases this is likely to be limited to the name, contact email and/or phone number, date and amount of the financial transaction.
In the event your Your account being terminated or deleted, it cannot be reinstated and the data You had previously provided will not be able to be restored. If You wish to use Adeption, You will need to create a new User account.
Adeption stores information about visitors to Our Services and Users on servers located in Dublin, Ireland. By using our Services, you consent to storage of Your information in Ireland. If You are using the Services from outside Ireland, please know the data and personal information You submit will be transferred to and stored in servers in Ireland or other countries. The data protection and other laws of Ireland 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 Ireland. Our service provider for data storage complies to all know data protection and storage laws.
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 Adeption Courses, You agree to this transfer, storing or processing.
California residents (through the California Civil Code Section 1798.83) have the right to receive, once a year from Us: a) information identifying any third party company(ies) to whom Adeption may have disclosed (within the previous calendar year) Your personal information for that company's direct marketing purposes; and b) a description of the categories of personal information disclosed. If You are a California resident and wish to obtain such information, submit a request to Us at email@example.com; when you request the information, use the phrase “California Shine the Light Request” to help us appropriately identify your question, and include your mailing address, state of residence and email address so we can provide a response.
Adeption commits to resolve complaints about our collection or use of your personal information. Individuals with inquiries or complaints regarding their Privacy and Use of Data policy should first contact Adeption at firstname.lastname@example.org attention to our Legal Team. You may also contact Us via postal mail at KtoAct Limited. Attn: Legal, 1 Belvedere Drive Suite 200, Mill Valley, CA 94941.
Adeption has further committed to refer unresolved Privacy complaints to AAA-ICDR, an alternative dispute resolution provider. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit http://go.adr.org/privacyshield.html for more information or to file a complaint. The services of AAA-ICDR are provided at no cost to you.
Effective Date: September 5th, 2017
Cookies are small text files placed onto your computer or device as you browse the Internet. Cookies can be used to collect, store and share bits of information about your activities across websites and services, including on Adeption. They also allow us to remember things about your visit to Adeption, such as your preferred language and other choices/settings and generally make the site easier for you to use.
Adeption uses both session cookies and persistent cookies. A session cookie is used to identify a particular visit to Adeption. These cookies expire after a short time, or when you close your web browser after using Adeption. We use these cookies to identify you during a single browsing session, such as when you log into Adeption. A persistent cookie will remain on your devices for a set period of time specified in the cookie. We use these cookies where we need to identify you over a longer period of time. For example, we would use a persistent cookie if you asked that we keep you signed in.
For example, these technologies help authenticate your access to Adeption and prevent unauthorized parties from accessing your accounts.
For example, cookies help us remember your preferred language or the country that you are in. We can then provide you with content in your preferred language without having to ask you each time you visit Adeption.
For example, cookies help us test different versions of Adeption to see which particular features or content users prefer. We may include web beacons in e-mail messages or newsletters to determine whether the message has been opened and for other analytics. We might also optimize and improve your experience on Adeption by using cookies to see how you interact with Adeption, such as when and how often you use them and what links you click on.
We don’t release the information collected from our own cookies to any third parties, other than to our service providers who assist us in these activities.
We will notify you of any changes by posting the new Policy on Adeption with a new effective date. If we make a material change to this Policy, we will take reasonable steps to notify you in advance of the planned change.