PRIVACY POLICY OF SOMM360 YOUR EDUCATIONAL PARTNER

Version updated on [October 7th, 2020]

A World Exquis Inc. (“SOMM360” or “we”), owner and operator of the website available at www.somm360.com and the mobile application associated therewith (the “Platform”), places particular importance on the protection of your Personal Information. That is why we are committed to ensure the accuracy, security and confidentiality of the Personal Information collected about you, in accordance with applicable laws.

This Privacy Policy (the "Policy") defines how SOMM360 collects, uses, discloses and retains your Personal Information and is intended to help you understand our practices. This Policy also explains how you can ask questions and make suggestions about our privacy practices and review or update your Personal Information.

This Policy does not apply to third-party websites and software that may be accessed through the Platform. Be aware that if you click on a link to a third-party site, you will be taken to websites we do not control

For the purposes of this Policy, “Personal Information" means any information about an identifiable individual or that, taken alone or in combination with other data, allows an individual to be identified. Generally speaking, personal information does not include business contact information such as your name, title, business address or telephone number.

SOMM360 has appointed a Chief Privacy Officer. If you have any questions, comments or complaints about this Policy, please contact the following email: [email protected]

1. THE PERSONAL INFORMATION WE COLLECT

In the course of our business and service provision, the Personal Information collected may include, but is not limited to:

  • Your contact information, including your name, username, email address, country, province/state and IP address;
  • Your biography;
  • Your age;
  • Your gender;
  • Your use of the Platform and other technical information related to your browsing behaviour;
  • Any other personal information provided.

Our Platform not intended for individuals under the age of majority in the jurisdiction of their domicile, and in any case, we do not knowingly collect Personal Information from children under 16. If we learn that we have accidentally collected Personal Information from a child under age 16 without verification of parental consent, we will delete that information. If you believe that we might have any information from or about a child under 16, please notify our Chief Privacy Officer at the email address mentioned above.

2. HOW WE COLLECT AND USE YOUR PERSONAL INFORMATION

Personal Information collected by SOMM360 will be used for the following purposes:

  • Provide, maintain, customize and improve our services;
  • Allow SOMM360 to perform internal operations related to its services; and
  • Send or facilitate communications between SOMM360 and you in connection with the services.

SOMM360 collects your Personal Information from you and through cookies and the Google Analytics tool.

2.1 From you

You provide us directly with Personal Information, such as when you create an account on the Platform, when you click on an advertisement that we have placed on a third-party website (e. g. Google, Facebook, etc.), when you contact us or any other way you use our services.

2.2 Cookies and other social media features

Cookies, or similar technologies (e.g., web beacons, pixels, ad tags and device identifiers) are small files that a site or its service providers transfers to your computer’s hard drive through your Web browser that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. Although we collect Personal Information provided by cookies, note that we do not collect personally identifiable information automatically from cookies or other social media features.

For example, we use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer you better site experiences and tools in the future. We also use cookies for analytics and reporting purposes. In other words, we may analyze information such as how often you visit the Platform. They are also used to help us understand your preferences based on previous or current Platform activity, interests, needs, as well as accelerate your future activities, which enables us to provide you with improved services.

In more details, SOMM360 uses two different types of connection cookies:

  • Performance and functionality connection cookies: These cookies are not essential to the provision of our services. They facilitate the personalization and enhancement of the user experience. For example, they may remember your preferences and avoid having to re-enter information more than once or remember your credentials, so they don't have to enter them each time you use them.
  • Cookies for advertising purposes: These cookies are not essential to the provision of our services. They use information about your visit to the Platform, such as the pages visited or the response to advertisements, to help provide the best user experience for your situation.

For these purposes, we use, among others, the following tools : Zoho SalesIQ, Zoho PageSense and Zoho Campaigns.

SOMM360 mainly uses 2 types of cookies:

  • Session cookies: This cookie is stored in the memory for the duration of your visit, after which it is deleted from your device. It allows us to identify you and is then deleted once you leave the Platform.
  • Persistent cookies: This cookie is stored on your device until it expires and will be retrieved the next time you visit the Platform. The duration of our persistent cookies varies upon their purpose.

If you wish to disable the use of cookies, you can do so from your browser's preference menu. You may disable cookies or use private browsing mode when accessing the Platform.

Our services also include social media features like the Facebook share button or interactive mini-programs that run on the Platform. If you use those features, they will collect your IP address, which page you are visiting on the Platform, and set a cookie to enable those features to function properly. These features may be hosted by a third party or hosted directly on the Platform. Your interaction with these features is governed by the privacy policy of the company proving the feature and not by this Policy.

2.3 Use of Google Analytics

We use Google Analytics to analyze the browsing behaviour of visitors to the Platform. It is a tool for analyzing the navigation and use of Websites, which is provided by Google Inc. By using this tool, SOMM360 can obtain, among other things, the following information:

  • The number of visitors to the Platform;
  • The type of browser, language and operating system you are using;
  • Screen resolution
  • The name of the service provider;
  • Date, time and duration of visits;
  • The country/province from which the Platform is being accessed
  • Age/gender
  • The pages visited;
  • The source (origin) of the traffic, either organic/direct/reference/social media;
  • Centres of interest;
  • Search terms within the Platform (search fields).

The information collected by Google Analytics is used to analyze the use of the Platform and to produce statistical reports on visitor activity. You can obtain more information about Google Analytics here.

Except as already provided by applicable privacy legislation, SOMM360 will request your consent before using your Personal Information for purposes not previously identified.

3. YOUR CONSENT TO THE COLLECTION AND USE

Your consent to the collection, use and disclosure of your Personal Information is required, except where inappropriate (for example, for legal or security reasons, it may be impossible or impractical to obtain consent).

BY ACCESSING THE PLATFORM OR OTHERWISE USING SOMM360’S SERVICES, YOU EXPRESSLY PROVIDE US WITH YOUR CONSENT TO COLLECT, PROCESS AND USE YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THE PROVISIONS OF THIS POLICY.

You represent that you are aware of the purposes for which SOMM360 collects, processes and uses your Personal Information, how it will be collected and how we protect the confidentiality of the Personal Information.

You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice.

4. RETENTION OF PERSONAL INFORMATION

Personal Information will be retained as long as necessary for the fulfillment of the identified purposes or for compliance with legal requirements regarding retention periods.

Any user may request that their account be deleted by sending a request to SOMM360 by email.

5. OUR SECURITY MEASURES

SOMM360 implements industry-standard, state-of-the-art security measures to protect its customers from unauthorized access or use, alteration, unlawful or accidental destruction or loss of their Personal Information.

Unfortunately, it is impossible for us to guarantee the absolute security of the Personal Information collected or transmitted through the Platform.

You therefore understand and agree that (i) there are limits to the security and confidentiality of the Personal Information we collect that are beyond the control of SOMM360; (ii) the security, integrity and confidentiality of all Personal Information and data exchanged between you and SOMM360 through the Platform cannot be guaranteed; and (iii) such Personal Information may be viewed or altered by a third party at the time of transfer. For these reasons, SOMM360 cannot be held responsible for any loss, capture or alteration of Personal Information.

6. ACCESS AND MODIFICATION OF PERSONAL INFORMATION

You have access to your Personal Information through your user account on the Platform, if applicable. You can correct and update this Personal Information from this access.

You may obtain a copy of your Personal Information or have it corrected, if it is incorrect, by sending us a written request by e-mail.

No request for access, rectification or deletion may be considered unless it is made in writing by you when you prove that you are the individual concerned (or the representative, heir or successor of that individual, or the liquidator of the succession, a beneficiary of life insurance or of a death benefit).

When we receive a request for access, rectification or removal, we will attempt to respond within a reasonable timeframe after receipt of the request.

In certain situations, SOMM360 may not be able to provide access to all the Personal Information it holds about you. Exceptions to the access requirement are meant to be limited and specific. The reasons for denying access will be provided to you upon request.

Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons and information that is subject to solicitor-client or litigation privilege.

A reasonable fee may be charged for the transcription, reproduction or transmission of Personal Information.

7. PERSONAL INFORMATION DISCLOSURE

SOMM360 will not disclose your Personal Information to a third party unless you consent, or unless such disclosure or use is required by law.

8. POLICY CHANGE AND UPDATE

SOMM360 may, at its discretion, update, revise, modify or supplement this Policy from time to time. We recommend that you review it whenever you visit the Platform to stay informed about how we handle Personal Information.

The continued use of the services provided by SOMM360, after the amended Policy comes into effect, constitutes consent to such amended Policy.

9. POSSIBILITY TO FILE A COMPLAINT

To contact us, ask questions about this Policy, provide us with your comments, submit a request for access or correction, exercise any applicable rights, file a complaint or obtain information about our practices or policies, we invite you to contact our Chief Privacy Officer.

10. EUROPEAN UNION DATA

This Section only applies to Personal Information that is collected or processed on an individual located in the territory of the European Union at the time of such collection.

10.1 Right to erasure

With some restrictions applicable, in accordance with the international application of the General Data Protection Regulation, you will be entitled to obtain from SOMM360 the prompt deletion of your Personal Information and SOMM360 is required to delete such Personal Information as soon as possible, where any of the following reasons apply:

  • the Personal Information is no longer necessary for the purposes for which it was collected or otherwise processed;
  • you withdraw the consent on which the processing is based and there is no other legal basis for the processing;
  • you object to the Processing and there is no compelling legitimate reason for the Processing;
  • the Personal Information has been unlawfully processed;
  • the Personal Information must be deleted to comply with a legal obligation to which SOMM360 is subject; and
  • the Personal Information was collected as part of an offer of services normally provided for remuneration, remotely, electronically and at the individual request of a recipient of services.

Where SOMM360 has made the Personal Information public and is required to delete it, SOMM360, taking into account the available technologies and the costs of implementation, will take reasonable steps, including technical measures, to inform the data controller who process such Personal Information that you have requested that such data controller delete any link to or copy or reproduce such Personal Information.

10.2 Right to restrict processing

You will be entitled to obtain from SOMM360 a restriction to process when any of the following applies:

  • for a period of time that allows SOMM360 to verify the accuracy of the personal data while you dispute the accuracy of the Personal Information;
  • the processing is unlawful and you object to the deletion of Personal Information and instead require a restriction to process by limiting the Personal Information use;
  • SOMM360 no longer requires the Personal Information for the purposes of the processing, but it is still necessary for you to establish, exercise or defend legal rights;
  • you object to the processing during a verification as to whether the legitimate grounds pursued by SOMM360 prevail over your own.

10.3 Right to Data Portability

You will be entitled to receive the Personal Information you have provided to SOMM360, in a structured, commonly used and machine-readable format, and you will be entitled to transmit such Personal Information to a third party without SOMM360 impeding it where the processing is based on your consent and the processing is carried out using automated processes.

10.4 Right to Object

You may object, at any time, for reasons relating to your particular situation, to the processing of your Personal Information which is necessary for the legitimate interests pursued by SOMM360 or by a third party or for the performance of a task carried out in the public interest or in the exercise of a public authority vested in SOMM360, including profiling. SOMM360 will no longer process Personal Information unless we demonstrate that there are compelling legitimate reasons for the processing that prevail over your interests, rights and freedoms or for the establishment, exercise or defence of legal rights.

10.5 Automated Individual Decision-Making, Including Profiling

You may not be the subject of a decision based exclusively on automated processing, including profiling, that produces legal effects concerning you or significantly affects you in a similar manner, unless the decision is:

  1. necessary for the conclusion or performance of a contract between you and SOMM360;
  2. authorized by the law to which SOMM360 is subject and which also provides for appropriate measures to safeguard your rights, freedoms and legitimate interests; or
  3. based on your explicit consent.