Privacy Policy

Purpose

The purpose of this Privacy Policy is to describe how Fret Dojo (“Fret Dojo”, “us”, “we”, or “our”) collects, uses and shares information about you through our online interface (www.fretdojo.com) owned and controlled by us (referred to herein as the “website”).  Please read this Privacy Policy carefully to understand what we do. If you do not understand any aspect of our Privacy Policy, please feel free to contact us at support@fretdojo.com.  Your use of our website (www.fretdojo.com) is also governed by our Terms of Use.

Fretdojo operates out of and is located in New South Wales, Australia.   If you reside or are located in the European Economic Area (“EEA”), Fretdojo is the data controller of all Personally Identifiable Information (as defined below) collected via the website and of certain Personally Identifiable Information collected from third parties, as set out in this Privacy Policy.

What Information this Privacy Policy Covers

This Privacy Policy covers information we collect from you through our website. Some of our website’s functionality can be used without revealing any Personally Identifiable Information, though for features or services related to our courses, Personally Identifiable Information is required.  In order to access certain features and benefits on our website, you may need to submit or we may collect Personally Identifiable Information (i.e., information that can be used to identify you). Personally Identifiable Information can include information such as your name and email address, among other things. You are responsible for ensuring the accuracy of the Personally Identifiable Information you submit to Fret Dojo. Inaccurate information may affect your ability to use our website, the information you receive when using our website, and our ability to contact you. For example, your email address should be kept current because that is one of the primary means by which we communicate with you.

What You Consent to by Using Our Website

Please understand that by submitting any Personally Identifiable Information to us, you consent and agree that we may collect, use and disclose such Personally Identifiable Information in accordance with this Privacy Policy and our Terms of Use, and as permitted or required by law. If you do not agree with these terms, then please do not provide any Personally Identifiable Information to us. If you refuse or withdraw your consent, or if you choose not to provide us with any required Personally Identifiable Information, we may not be able to provide you with the services that can be offered on our website.  Consent can be withdrawn at any time per the discussion contained at “Updating or Deleting Your Personally Identifiable Information” found below.   Please note that we may also rely on legitimate interests or fulfilment of a contract to continue processing your data.

What Information We Collect

We gather two types of information about users through our website:

Information Relating to Your Use of our Website.

When users come to our website, we may track, collect and aggregate information indicating, among other things, which pages of our website were visited, the order in which they were visited, when they were visited, and which hyperlinks were “clicked.” We also collect information from the URLs from which you linked to our website. Collecting such information may involve logging the IP address, operating system and browser software used by each user of the website. We may be able to determine from an IP address a user’s Internet Service Provider and the geographic location of his or her point of connectivity.

We may also use cookies and web beacons when you visit our website. For more information on our use of cookies and web beacons, please refer to our Cookie Policy.

Personally Identifiable Information provided directly by you or via third parties. We collect Personally Identifiable Information that you provide to us when you register for an account, update or change information for your account, purchase products or services, complete a survey, sign-up for email updates or online courses, participate in our public forums, send us email messages, and/or participate in online courses or other services on our website.

We may use the Personally Identifiable Information that you provide to respond to your questions, provide you with the specific course and/or services you select, send you updates about special offers, FretDojo products and services, online courses offered by Fret Dojo or other Fret Dojo events, products or services offered by affiliates and business partners of Fret Dojo, and send you email messages about website maintenance or updates. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).

We may use your Personally Identifiable Information to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. 

Account Registration. If you register for an account on our website, you may be required to provide us with Personally Identifiable Information such as your name and email address.

Updates. Fret Dojo may offer you the ability to receive updates either via email or by postings on portions of our website that are only accessible to registered users. In order to subscribe to these services, you may be required to provide us with Personally Identifiable Information such as your name and email address.

Forums. Fret Dojo may offer public forums from time to time (the “Forums”) where you can share comments and thoughts. In order to participate in the Forums, you may be required to register with us and/or provide us and other third party providers with Personally Identifiable Information such as your name and email address.  Keep in mind that information you post or make available in Forums will be publicly available. You should not post any information of a personal or sensitive nature, whether relating to you or another person, on a forum.  Please also reference our Terms of Use for our Rules for Online Conduct and additional information about proper use of our Forums.

Participation in Online Courses and Clubs.  Fret Dojo offers users the opportunity to participate in online courses and clubs on or through our website. If you desire to participate in a course or club, you will be asked to provide us with certain information necessary for you to participate in the course or club. This information may include, among other things, your name and email address.

If you participate in an online course or club, we may collect from you certain student-generated content, such as assignments you submit and student feedback. We may also collect course data, such as student responses to questionnaires and surveys.  You should not include any Personally Identifiable Information or other information of a personal or sensitive nature, whether relating to you or another person, on assignments you submit and in responses to questionnaires and surveys, except for information required to participate or submit such assignments and responses.

Identity Verification.  Fretdojo may offer you the ability to verify your identity for selected courses.  In order to enroll for these services, you may be required to provide us or our third-party identity verification vendor with Personally Identifiable Information such as your name, address, date of birth, a headshot taken using a webcam, and a photo identification document.  

Communications with Fret Dojo. Fret Dojo may receive Personally Identifiable Information when you send us an email message or otherwise contact us.

Third Party websites.  Fret Dojo may receive Personally Identifiable Information when you access or log-in to a third party website, e.g., Zoom. This may include the text and/or images of your Personally Identifiable Information available from the third party website.

Surveys. Fret Dojo may receive Personally Identifiable Information when you provide information in response to a survey operated by us.

Partner websites. Partner websites providing online course and club related tools and services to Fret Dojo users may collect nonfinancial individual level user data regarding the individual’s use of that partner website while engaged with such online course and club related activities, and the partner websites may share that data with Fret Dojo for the purpose of improving Fret Dojo’s services, the partner website’s services, and the individual student’s educational experience. This data includes information such as the amount of time spent on the partner website and pages viewed.

Third Party Credit Card Processing. Fret Dojo provides you with the ability to pay for online courses, clubs and other services using a credit card through a third party payment processing service provider. Please note that our service provider – not Fret Dojo – collects and processes your credit card information.

How We Use the Information

Information Relating to Your Use of Our Website.  We use information relating to your use of our website to build higher quality, more useful services by performing statistical analyses of the collective characteristics and behavior of our users, and by measuring demographics and interests regarding specific areas of our website. We may also use it for other business purposes, including ensuring the security of our services and our website.

Personally Identifiable Information Provided Directly by You or Via Third Parties.  Except as set forth in this Privacy Policy or as specifically agreed to by you, Fret Dojo will not disclose any of your Personally Identifiable Information. In addition to the other uses set forth in this Privacy Policy, we may disclose and otherwise use Personally Identifiable Information as described below.

Providing the Website and Our Services. We use Personally Identifiable Information which you provide to us in order to allow you to access and use the website and in order to provide any information, products or services that you request from us.

Updates.  We use Personally Identifiable Information collected when you sign-up for our various email or update services and our online courses and clubs to send you messages in connection with our website and our online courses and clubs We may also archive this information and/or use it for future communications with you, where we are legally entitled to do so.

Forums. You should not post any Personally Identifiable Information or other information of a personal or sensitive nature, whether relating to you or another person, within a forum post.  If you choose to post Personally Identifiable Information, such Personally Identifiable Information may be collected during your use of our forums. We may publish this information via extensions of our Platform that use third-party services, like mobile applications. We also reserve the right to reuse forum posts containing Personally Identifiable Information in future versions of our courses that we offer, and to enhance future course offerings. We may archive this information and/or use it for future communications with you and/or provide it to the instructor(s) associated with the courses you have taken and the clubs you join. We may also use or publish posts submitted on the forums without using Personally Identification Information.

Participation in Online Courses. We use the Personally Identifiable Information that we collect from you when you participate in an online course or club through the website for processing purposes, including but not limited to tracking attendance, progress, and completion of an online course. We may also share your Personally Identifiable Information and your performance in a given online course or club with the course and club instructor or instructors who taught the course, with teaching assistants or other individuals designated by the instructor or instructors to assist them with the creation, modification or operation of the course or club. We may also archive this information and/or use it for future communications with you, where we are legally entitled to do so.

Identity Verification. For services that require identity verification, we use the Personally Identifiable Information that we collect for verifying your identity, and for authenticating that submissions made on the website were made by you. This service may be provided through a third-party identity verification vendor. If you have provided a photo identification document, your photo identification document will be deleted after successful verification of your profile information.

Communications with Fretdojo. When you send us an email message or otherwise contact us, we may use the information provided by you to respond to your communication and/or as described in this Privacy Policy. We may also archive this information and/or use it for future communications with you where we are legally entitled to do so.

Communications with Fretdojo Business Partners. We may share your Personally Identifiable Information with business partners of Fret Dojo so that Fret Dojo’s business partners may share information about their products and services that we believe may be of interest to you, where we are legally entitled to do so.

Research. We may share general course data (including submissions and forum discussions), information about your activity on our website, and demographic data from surveys operated by us with our business partners so that our business partners may use the data for research related to online education.

Disclosure to Fretdojo Operations and Maintenance Contractors. We use various service providers, vendors and contractors (collectively, “Contractors”) to assist us in providing our products and services to you. Our Contractors may have limited access to your Personally Identifiable Information in the course of providing their products or services to us, so that we in turn can provide our products and services to you. These Contractors may include vendors and suppliers that provide us with technology, services, and/or content related to the operation and maintenance of our website and/or online course and club access. Personally Identifiable Information made available to these Contractors is limited to the information reasonably necessary for them to perform their limited function for us.

Government Authorities, Legal Rights and Actions. We may share your Personally Identifiable Information with various government authorities in response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights or to protect our property; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us. We also may share your Personally Identifiable Information when we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of Fret Dojo, the website, our users, customers, or others; and in connection with our Terms of Use and other agreements.

Disclosure to Acquirers. Fret Dojo may disclose and/or transfer your Personally Identifiable Information to an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of the equity, business or assets of Fret Dojo to which your Personally Identifiable Information relates.

e-Readers. If we receive any Personally Identifiable Information related to your use of designated e-Readers to access Fret Dojo materials, we may archive it, and use it for research, business, or other purposes.

External Links

For your convenience we may provide links on our website and in communications to you to websites operated by organizations other than Fret Dojo (“Third Party websites”) that we believe may be of interest to you. We do not disclose your Personally Identifiable Information to these Third Party websites without obtaining your consent. We do not endorse and are not responsible for the privacy practices of these Third Party websites. If you choose to click on a link to one of these Third Party websites as it may be provided to you by us, you should review the privacy policy posted on the Third Party website to understand how that Third Party website collects and uses your Personally Identifiable Information.

Retention of Personally Identifiable Information

If you reside or are located in the EEA, we keep your Personally Identifiable Information for no longer than necessary for the purposes for which the Personally Identifiable Information is processed. The length of time we retain Personally Identifiable Information for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.

Confidentiality & Security of Personally Identifiable Information

We consider the confidentiality and security of your information to be of the utmost importance. We will use industry standard physical, technical and administrative security measures to keep your Personally Identifiable Information confidential and secure and will not share it with third parties, except as otherwise provided in this Privacy Policy, or unless  such disclosure is necessary in special cases, such as a physical threat to you or others, as permitted by applicable law. Because the Internet is not a 100% secure environment we cannot guarantee the security of Personally Identifiable Information, and there is some risk that an unauthorized third party may find a way to circumvent our security systems or that transmission of your information over the Internet will be intercepted. It is your responsibility to protect the security of your login information. Please note that e-mails and other communications you send to us through our website are typically not encrypted and should not be considered secure.

Updating or Deleting Your Personally Identifiable Information

You have certain rights in relation to your Personally Identifiable Information.  You can access your Personally Identifiable Information and confirm that it remains correct and up-to-date or choose whether or not you wish to receive material from us or some of our partners by logging into the website and visiting your user account page.  If you would like further information in relation to your rights or would like to exercise any of them, you may also contact us via privacy@fretdojo.com

If you reside or are located in the EEA, you may contact us at privacy@fretdojo.com and request that we:

  • Provide access to any Personally Identifiable Information we hold about you;
  • Prevent the processing of your Personally Identifiable Information for direct-marketing purposes;
  • Update any Personally Identifiable Information which is out of date or incorrect;
  • Delete any Personally Identifiable Information which we are holding about you;
  • Restrict the way that we process your Personally Identifiable Information;
  • Provide your Personally Identifiable Information to a third party provider of services; or
  • Provide you with a copy of any Personally Identifiable Information which we hold about you.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to answer every email promptly where possible, and provide our response within the time period stated by applicable law.  Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.  Keep in mind, however, that there will be residual information that will remain within our databases, access logs and other records, which may or may not contain your Personally Identifiable Information.  Please also note that certain Personally Identifiable Information may be exempt from such requests in certain circumstances, which may include if we need to keep processing your Personally Identifiable Information to comply with a legal obligation.

Questions, Suggestions and Complaints

If you have any privacy-related questions, suggestions, unresolved problems, or complaints you may contact us via privacy@fretdojo.com.

If you reside or are located in the EEA, our Data Protection Officer and Privacy Team may assist with all queries regarding our processing of Personally Identifiable Information at security@fretdojo.com.

If you reside or are located in the EEA, you may also make a complaint to our supervisory body for data protection matters or seek a remedy through local courts if you believe that your rights have been breached.

California Privacy Rights

Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g. requests made in 2018 will receive information regarding 2017 sharing activities).

To obtain this information, please send an email message to privacy@fretdojo.com with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response.  Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

International Privacy Practices

Fret Dojo’s websites are primarily operated and managed on servers located and operated within the United States. In order to provide our products and services to you, we may send and store your Personally Identifiable Information (also commonly referred to as personal data) outside of the country where you reside or are located.  Accordingly, if you reside or are located outside of the United States, your Personally Identifiable Information may be transferred outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your Personally Identifiable Information. We are committed to protecting the privacy and confidentiality of Personally Identifiable Information when it is transferred. If you reside or are located within the EEA and such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as you would have within the EEA to the extent feasible under applicable law. We participate in and commit to adhering to the EU-U.S. Privacy Shield Framework when transferring data from the EEA to the United States. Please see our Privacy Shield Policy for further information.

Changing Our Privacy Policy

Please note that we review our privacy practices from time to time, and that these practices are subject to change. Any change, update, or modification will be effective immediately upon posting on our website. We will notify you of any material change to this Privacy Policy by posting a notice on our website’s homepage for a reasonable period of time following such update, and by changing the effective date (located at the bottom of this page). Be sure to return to this page periodically to ensure familiarity with the most current version of this Privacy Policy.

No Information from Children Under 13

Fret Dojo strongly believes in protecting the privacy of children. In line with this belief, we do not knowingly collect or maintain Personally Identifiable Information on our website from persons under years of age, and no part of our website is directed to persons under thirteen (13) years of age. If you are under thirteen (13) years of age, then please do not use or access our website at any time or in any manner. We will take appropriate steps to delete any Personally Identifiable Information of persons less than thirteen (13) years of age that has been collected on our website without verified parental consent upon learning of the existence of such Personally Identifiable Information.

 

Effective as of 25 May, 2018.

 

Privacy Shield Policy

Introduction.

Fretdojo (referred to as “we,” “us,” or “our”), believes in protecting your privacy.

We participate in and commit to adhering to the EU-U.S. Privacy Shield Framework which includes the Privacy Shield Principles of notice, choice, onward transfer, security, data integrity, access and enforcement (the “Principles”) for all transfers of personal data from EEA to the U.S. To learn more about Privacy Shield, please visit the U.S. Department of Commerce Privacy Shield website:  https://www.privacyshield.gov/.

When we use the term “Personal Information” in this Privacy Shield Policy, we are referring to any information that:  (i) is recorded in any form; (ii) is about an identified or identifiable individual; and (iii) is received by us from the EEA.

When we use the term “Sensitive Personal Information” in this Privacy Shield Policy, we are referring to a particular subset of an individual’s Personal Information that provides details of his or her race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, or trade union membership or that concerns his or her health.

The purpose of this Privacy Shield Policy is to outline our general practices for implementing the Principles with respect to the Personal Information we collect. If you would like to obtain additional information regarding our privacy practices in connection with information collected on this website in general, please refer to our online Privacy Policy.

Principles.

  1. Notice. We will provide you with timely and appropriate notice in our Terms of Use and Privacy Policy, describing what Personal Information we are collecting, how we will use that information, and the types of third parties with whom we may share such information (and the reasons we do so). Please review these documents carefully. Where we process personal data on behalf of our business partners, we will work with them to help them provide appropriate notice to you.
  2. Choice. We will offer you the opportunity to opt-out of your Personal Information (or to provide explicit consent for Sensitive Personal Information) being: (i) disclosed to a third party (other than a service provider as set forth below); or (ii) used for a purpose materially different from the purpose for which it was originally collected (as set out in our Privacy Policy), or subsequently authorized by you, when the circumstances arise. You also have the ability to opt out at any time from the use of your personal information for direct marketing purposes. To exercise this right, please check your settings options. If you have further questions related to the above, you can also contact us at privacyshield@fretdojo.com.

Where we process personal data on behalf of our business partners, we will work with them to ensure you are offered appropriate choices (and means to exercise those choices) for limiting use or disclosure of your personal data (where appropriate).

Notwithstanding the foregoing, you agree that we may disclose Personal Information under the following circumstances without offering you an opportunity to opt out of such disclosure: (i) to our partner institutions and other service providers that we have retained to perform requested services on our behalf; (ii) if we are required to do so by law or legal process; (iii) pursuant to valid requests by law enforcement or other government authorities (which we are legally required to respond to); and (iv) when we believe disclosure is necessary to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity. In addition, we reserve the right to transfer Personal Information in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation). Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use the Personal Information in a manner consistent with this Privacy Shield Policy.

  1. Onward Transfers (Transfer to Third Parties). We will only transfer Personal Information to third parties where the third party: (i) has provided satisfactory assurances to us that it will protect the Personal Information in accordance with this Privacy Shield Policy and the Principles; (ii) is located in the EU or a country considered “adequate” for privacy by the EU Commission, and therefore is required to comply with the EU data protection laws or substantially equivalent privacy laws; or (iii) has certified to Privacy Shield, and is independently responsible for complying with the Principles.

Where we have knowledge that a third party to whom we have provided Personal Information is processing that Personal Information in a manner contrary to this Privacy Shield Policy or the Principles, we will take reasonable steps to prevent or terminate processing by the third party until such time the third party can process Personal Information in compliance with this Privacy Shield Policy and the Principles. Under certain circumstances, we may be potentially liable if these requirements are not met.

  1. Data Security. We will take reasonable and appropriate measures to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. We have implemented appropriate physical, electronic and managerial procedures to help safeguard and secure Personal Information from loss, misuse, unauthorized access or disclosure, alteration or destruction.
  2. Data Integrity and Purpose Limitation. We will process Personal Information in a manner that is compatible with and relevant to the purpose for which it was collected or authorized by you. To the extent necessary for those purposes, we will take reasonable steps to ensure that Personal Information is accurate, complete, current and reliable for its intended use.
  3. Access. Upon request, we will provide you with reasonable access to the Personal Information about you that we hold. We will also take reasonable steps to correct, update, amend or delete any information that is demonstrated to be inaccurate, except where the burden or expense of doing so would be disproportionate to the risks to your privacy in the case in question or where the rights of third parties would be violated. Where we process personal data on behalf of our business partners, we will work with them in complying with such requests in accordance with applicable law.
  4. Recourse; Enforcement. We will regularly review our compliance with the statements set forth in this Privacy Shield Policy, and we will provide an independent way to resolve complaints about our privacy practices. We encourage interested persons to first contact us (contact information provided below) and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles. If your inquiry is not satisfactorily addressed by us, it can in most instances be resolved through the Privacy Shield binding arbitration process. Please see the Privacy Shield website for further information: https://www.privacyshield.gov/article?id=C-Pre-Arbitration-Requirements

Modifications.

We may amend this Privacy Shield Policy from time-to-time in accordance with the requirements of the EU-U.S. Privacy Shield Framework. The most recent version of the Privacy Shield Policy will always be posted to this website. Anytime that we do make such changes, we will also update the effective date listed at the bottom of the Privacy Shield Policy. Please be sure to review the most recent version of the Privacy Shield Policy each time that you visit this website so that you are aware of how we collect, use and retain personal information.

Contact Us.

Please contact us with any questions or comments about this Privacy Shield Policy, transfer of your personal information from the EEA to the U.S., our privacy practices, or your consent choices by email at privacyshield@fretdojo.com.

Effective as of 25 May, 2018.

 

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