EFFECTIVE DATE: 2/22/2022

This Privacy Policy (the “Policy”) describes how Dance: The Cutting Edge, Inc. (“DTCE” or “we” or “our” or “us”) collects, stores, shares, and uses information, and includes your choices about privacy when you use our website, products, and services (collectively, the “Services”). This Policy is part of and incorporated into our Terms and Conditions, which can be viewed at: https://dancethecuttingedge.com//terms-and-conditions. 

DTCE knows that you care about and are concerned with how your personal information is used and shared. Your privacy is important to us, and we ask that you read this Policy carefully to be informed about our practices. By visiting, transacting, or otherwise utilizing on dancethecuttingedge.com (the “Website”), you (the “User” or, collectively, “Users”) acknowledge that you accept and agree to all of the practices and policies outlined in this Policy and hereby consent to the collection, use, and sharing of your information as described herein. 

1. What Does This Privacy Policy Cover?

This Policy covers our collection and use of personally identifiable information (“Personal Information”) when you access our Website and use our Services, and which Personal Information is either provided to us by you or collected automatically because you have visited, interacted with, or transacted on the Website. This Policy does not apply to the practices of third parties that we neither own or control, or to individuals that we do not employ. 

      2. What Personal Information Do We Collect?

The Personal Information we collect from Users of the Website enables us to personalize and improve our Services, to allow our Users to transact on the Website, and to allow our Users to register a user account and create a profile. Personal Information does not include information that has been aggregated or made anonymous so that by itself it no longer identifies and can no longer reasonably be used to contact a specific person or household.

We collect the following types of information from our Users:   

   A. Personal Information You Provide Us:

       i. In order to transact on the Website, you are required to create an account and provide Personal Information voluntarily to us in order to do so. This Personal Information includes but is not limited to your name, shipping address, credit-card information, a valid email address, and telephone number. We do not intentionally store credit-card information. Payment information is stored by a third-party payment processor, Stripe, and the use and storage of this payment information is subject to their own terms of service and privacy policy. You always have the right to decline to provide us with information; however, should you choose to withhold Personal Information you may not be able to transact on the Website, take advantage of special features, or enjoy the full experience of the Website.

   B. Information Collected Automatically by Us:

       i. Whenever you view, access, or interact with our Website, we automatically collect information such as your IP address and web browser, which information is then stored by us. How you move through the Website, what pages you visit, and what items you click on, is data which is automatically collected and stored by us and linked to your user profile. This data is used to improve our services and your experience of the Website. This information also allows us to better personalize the marketing materials you may receive from us.

       ii. We may place, or allow our technology and advertising partners to place, on your computer “cookies” and “web beacons” (also known as Internet tags, pixel tags, single-pixel GIFs, clear GIFs, invisible GIFs, 1-by-1 GIFs, and web bugs), which are identifiers transferred to your computer through your browser that allow us to undertake reporting, including but not limited to the ability to recognize your browser and tell us how, when, and which pages of our Website are visited, advertisements that are viewed, and how many people are active on our Website at any given time. These identifiers do not contain Personal Information about you. You may change your preferences on your web browser to manage cookies, web beacons and similar technologies, but doing so may restrict your use of the entirety of the features we offer on our Website.

       iii. When we collect such usage information, we use this data in anonymized and aggregated form, and not in a manner that can identify you or your household. We may also provide this anonymized and aggregated information to our third-party service providers in the normal course of business of providing our services to you. We do not disclose anonymized or aggregated information to a third-party service provider in a manner that can identify you or your household.

   C. Email: 

       i. When you interact with an email from us, we may receive a confirmation that you have done so, the purpose of which is to allow us to make our communications more tailored to your needs as well as to improve our services. If at any time you no longer wish to receive emails from us, you may use the unsubscribe functionality at the bottom of the email received. However, if you transact on our website, we are permitted to email you regarding that transaction regardless of whether or not you have chosen to unsubscribe from other emails.

   D. Personal Information Received from Other Sources:

       i. When we work with third-party service providers, we may obtain information about you, including but not limited to demographic information, contact information, publicly available data, and email addresses. We may use this information for legitimate business purposes, including the performance of a contract, customer support, marketing and fraud prevention in connection with the Website. If you receive an email from us which was sourced from a third-party service provider and wish to opt out, please use the unsubscribe functionality found at the bottom of the email to do so.

       3. Will We Share Any of the Personal Information We Receive?

WE NEITHER RENT NOR SELL YOUR PERSONAL INFORMATION TO ANYONE, however we may share your Personal Information with third-party service providers as described below. For any such third-party service providers, we encourage you to visit their respective websites to review their terms of use and/or privacy policies. If you would like any information about our third-party service providers you may contact us at info@dancethecuttingedge.com.

Except as set forth in this Policy, we will use commercially reasonable efforts to notify you when your Personal Information may be shared with third parties and shall be given an opportunity to opt-out of such a transfer. 

   A. Affiliated Businesses We Do Not Control: In certain situations, businesses with which we are affiliated may sell items to you via the Website (either for their own benefit or in partnership with us). We will use commercially reasonable efforts to make any such information clear to you when an affiliated business is associated with such a transaction in order for you to determine if you wish to finalize the transaction as we will share your Personal Information with that affiliated business only to the extent that it is related to such transaction. 

   B. Third-Party Service Providers: We engage with third-party service providers to undertake work on our behalf and in doing so may be required to share Personal Information with them in furtherance of their work with us and in order to provide products and services to you. Unless we inform you otherwise, these third-party service providers may only use the Personal Information we share with them to provide their services to us.

   C. Communication about the Website: As part of the Website and our services, you may receive communications from us, by both email and regular mail. We and our agents may send you email, contact you, or engage you in other communication that we or they determine relates to your use of the Website. If you would like to opt-out of these communications, you may unsubscribe from any emails via the unsubscribe functionality on the email itself or by sending us your request to info@dancethecuttingedge.com.

   D. Promotional Offers: We may send you offers on behalf of other businesses. However, when we do so, we do not give the other business your Personal Information. If you do not wish to receive these offers, you may unsubscribe via the unsubscribe functionality on the email itself or by sending us your request to us via email at info@dancethecuttingedge.com.

   E. Business Transfers: We retain the exclusive right to engage in a merger, acquisition, or sale of any or all of our assets at any time. Should such a sale take place and you have a registered user account with us: (1) we will notify you of such a sale to the most recent email address you have provided to us, and (2) you are advised that your Personal Information will be included in that sale of assets, though we do not consider such a transfer to be a “sale” of your Personal Information as that word is generally understood. 

   F. Protection of DTCE and Others: We may release Personal Information when we believe in good faith that release is necessary to comply with the law; enforce our Terms of Use or other agreements; and to protect the rights, property, or safety of DTCE, our employees, our users, and others as situations arise. This includes but not is not limited to sharing information with third parties to mitigate fraudulent activities on the Website. If any such information is determined to be “confidential” as it is described under the applicable law, DTCE will take all steps necessary to protect that information while complying with the applicable law.

Legal Basis for Processing Personal Information 

Our legal reasoning for collecting and using Personal Information as described depends on the personal information in question and the specific context in which it is collected.

We will collect Personal Information only where we have your consent to do so, where the Personal Information is necessary for us to perform a service, and where otherwise described in this Privacy Policy. 

We may use all of the Personal Information that we obtain from or about you in order to fulfill our contractual obligations, for legitimate business purposes, or as required:

• to provide our Services to you, including new Services we may develop later;
• to provide you with customer support;
• to facilitate your communications or transactions with us;
• to operate, improve, and customize our Services, content, and marketing, to develop new Services, and to understand how you use and interact with our Services and Content, and the products, services, and content of others;
• to develop and display more customized content and ads to you on or off our Website;
• to promote and maintain a trusted, safer, and more reliable environment on our Services, for example, to help detect, prevent or otherwise address fraud, security or technical issues, conduct investigations or risk assessments, or verify actions taken by you or associated with your account;
• to contact you (by email, postal mail, telephone, mobile devices, SMS text message, or as otherwise authorized by you) in order to address issues with your account or transaction or use of our Services, collect fees, send you updates about our Services or policies, or for other purposes permitted by law;
• to contact you (by email, postal mail, telephone, mobile devices, SMS text message, or as otherwise authorized by you) in order to send you marketing communications, promotional messages, and offers about our Services and content, and the products, services;
• to facilitate your participation in contests, sweepstakes or other promotional events sponsored or conducted by us or by others in conjunction with us;
• to comply with our legal obligations, resolve disputes, or enforce our Terms of Use or any other DTCE policies or agreements with Users; and
• to perform other functions as described when the information is collected or requested, or for other purposes with your prior consent.

DTCE recognizes the rights of our Users to: 

• Request access to the Personal Information collected on them by DTCE;
• Obtain a copy of the Personal Information held on them;
• Request the rectification or deletion of inaccurate or incomplete Personal Information;
• Withdraw consent given to DTCE for the collection of their Personal Information at any time, including the right to unsubscribe or to opt out of marketing communications and commercial publications of DTCE.

DTCE will respond to requests made by Users exercising their rights within a reasonable period of time after the individual’s request or within any specific period that may be required by applicable laws. DTCE will handle and investigate complaints made by individuals about any breach of these rules or data privacy laws and will respond to such complaints in a timely manner.

       4. COOKIE POLICY

By clicking “accept cookies,” you are consenting to our use of cookies in accordance with this Cookie Policy. If you do not agree to our use of cookies, you should set your browser settings accordingly as described here.

Most internet browsers are initially set up to automatically accept cookies. You can change browser settings to block cookies or to alert you when cookies are being sent to your device. There are a number of ways to manage cookies. Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings. If you use different devices to view and access the Website (e.g. your computer, smartphone, tablet etc.) you will need to ensure that each browser on each device is adjusted to suit your cookie preferences.

Although you are not required to accept cookies when you visit the Website, you may be unable to use all of the functionality of the website if you reject certain cookies.

We use cookies and similar tracking technologies to track the activity on our Website. The cookies we use or allow are an accepted part of ecommerce and important to your use of the Website. The information collected by cookies does not personally identify you; it includes general information about your computer settings, your connection to the Internet (e.g. operating system and platform, IP address, your browsing patterns, and timings of browsing on the website) and your location. Details about the types of cookies that DTCE utilizes can be found below.

What is a Cookie?

Cookies are pieces of data issued that may include an anonymous unique identifier. Cookies are used by a website that, among other things, allow your computer to utilize all the features on the website. If and when your computer accepts a cookie, the cookie may be stored on the computer’s hard drive.

Below we provide more information about the specific types of cookies utilized by the Website, and what those cookies do. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Website.

In addition to Cookies, our Website may utilize other technology to automatically track certain information such as Log File Information: DTCE’s servers automatically record certain information that your web browser sends whenever you visit the Website. These server logs may include information such as your web request, Internet Protocol (“IP”) address, browser type, browser language, referring / exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time of your request, and one or more cookies that may uniquely identify your browser.

Information Collected by “Clear GIFs”

DTCE may employ “clear GIFs” (a.k.a. Web Beacons), which are used to track the online usage patterns anonymously (i.e., in a non-personally-identifiable manner). In addition, DTCE may also use clear GIFs in HTML-based emails sent to users to track which emails are opened by recipients.

Data Collected via Website Technology

Each time a device visits the Website we may collect certain data from that device. This data is automatically collected from the device’s web browser and may include data such as the following:

• the type of web browser software the device uses (for example, Google Chrome or Internet Explorer);
• the name of the domain from which the device accessed the Internet;
• the Internet address of a third-party website from which the User was guided to the Website; and
• the date and time the device accessed the Website.

We may use this data to help us make the Website more useful to you and for other business purposes as described below.

Types of Cookies Utilized by DTCE Website

Cookies can either be session cookies or persistent cookies. A session cookie does not identify you personally and automatically expires when you close your browser. A persistent cookie will remain until it expires or you delete your cookies. By assigning your computer a unique identifier through a persistent cookie, we are able to create a database of your previous choices and preferences which can be provided by us automatically, saving you time and effort on future visits.

In addition, third parties may place and read cookies on your browser or use web beacons or similar technologies to collect data. We use a number of different third-party resources in order to utilize cookies, including Google Analytics. A description of the specific functionality of the cookies used by the Website is provided below.

Necessary Cookies

Necessary cookies enabling basic functions on the Website, like page navigation and access to secure areas. The Website cannot function properly without these cookies. Necessary cookies are used for the following purposes, including:

• Preserving your session state across page requests;
• Distributing traffic to the Website across several servers in order to optimize response times and improve your experience;
• Identifying trusted web traffic to keep the Website secure; and
• Storing your cookie consent state for the current web page you’re visiting.

Preference Cookies

Preference cookies enable the Website to remember information that changes the way the Website behaves or looks during your experience. Preference cookies are used to establish a unique user ID that recognizes you on returning visits in order to improve and personalize your experience.

Statistics Cookies

Statistic cookies help us understand how visitors interact with the Website by collecting and reporting information anonymously. Statistics cookies are used for the following purposes:

• Anonymously logging details about your browser and computer through Google Analytics; 
• Collecting anonymous data on your visits to the Website, such as the number of visits, average time spent on the Website, and what pages have been loaded, in order to generate reports for optimizing the Website’ content;
• Determining what type of device (smartphones, tablets, computers, TVs etc.) is being used to access the Website; and
• Gathering anonymous technical information regarding your browser, operating system, IP address and screen resolution as well as your navigation on the Website.

Advertising/Marketing Cookies

Marketing cookies are used to track visitors across the Website. The intention is to display ads that are relevant and engaging for individual users. Marketing cookies are used for the following purposes:

• Registering a unique ID that identifies your device for the purpose of targeted ads, auto-populating forms, validating if certain contact information is correct, keeping statistics about third party sites used/accessed through the Website;
• Registering anonymized user data, such as IP address, geographical location, visited websites, and what ads you have clicked, with the purpose of optimizing ad display based on your movement on websites that use the same ad network;
• Collecting data on your visits to the Website, such as what pages have been accessed, number of visits, average time spent on the Website, in order to categorize your interest and demographic profiles in terms of resales for targeted marketing, identifying traffic patterns on the Website, and carrying out surveys to better understand your preferences;
• Remarketing service to advertise on third party websites (including Google) to previous visitors to the Website;
• Evaluating efficacy of advertisements and likelihood of groups to engage with the Website and purchase DTCE products; and
• Registering your sharing of content via social media.

Third-Party Ad Networks

We may use data from Google’s Interest-based advertising or 3rd-party audience data (such as age, gender and interests) with Google Analytics. You can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads via Google Ads Settings, or opt out of general interest-based advertising via the NAI Consumer Opt Out. You may also be interested in the Google Analytics opt-out browser add-on.

     5. Is Personal Information About You Secure?

We endeavor to protect the privacy of your Personal Information that we hold in our records, but we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. The Website may contain links to other sites. We are not responsible for the privacy policies and/or practices on other sites. When linking to another site you should read that site’s privacy policy and/or terms of use.

     6. What Choices Do You Have?

You can always opt not to disclose information to use, but keep in mind that Personal Information may be required to use and take advantage of our Services, and the supplying of Personal Information is required in order to be able to transact on the Website.

If you do not wish to receive email from us, using the unsubscribe functionality found at the bottom of any email you may opt out of receiving email. If you no longer wish to receive mailings from us sent via post, please send us an email at info@dancethecuttingedge.com with your request. Please note that if you do not want to receive legal notices from us, such as this Policy, those legal notices will still govern your use of the Website, and you are responsible for reviewing such legal notices for any changes.

We will retain your data for (i) as long as your account is active; (ii) as long as is necessary to comply with any tax, legal, and/or other regulatory requirements; and (iii) to protect and defend against potential legal claims. By deleting your data from our Site, you understand that you will no longer be able to use our Services. We will retain your anonymized, aggregated, depersonalized data after it has been deleted from our Site. If you would like to request the deletion of your Personal Information or request that it be returned to you, contact us at info@dancethecuttingedge.com.

     7. Changes to This Privacy Policy

We may amend this Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make changes in the way we use Personal Information, we will notify you by posting an announcement on our Website. You are bound by any changes to the Privacy Policy when you use the Website after such changes have been first posted.

     8. California Consumer Privacy Act (CCPA) Privacy Notice

This Privacy Notice applies to California consumers and supplements the Privacy Statement.

Personal Information We Collect

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“CCPA personal information”). We have collected the following categories of CCPA personal information from consumers within the last twelve (12) months:

• Identifiers: “Identifiers” covers a broad range of information, including things like name, email address, postal address, telephone number, and IP address. We collect some CCPA personal information that falls into this category. For example, for subscribers we’re going to have an email address, payment information (like a credit card) and we may have a postal address. We collect IP addresses, identifiers from the devices you use to connect, and characteristics about the networks you use when you connect to our service online. These sorts of identifiers are connected to your DTCE account. There are also identifiers we use for purposes like advertising (resettable device identifiers, third party advertising cookies on our website) that we do not associate with your account, but that can be used to reach you with promotional messages on other websites and applications.

• Characteristics of protected classifications under California or federal law: This covers a broad range of information like race, sex, marital status, among other protected classes. We will collect this sort of information about you if you choose to participate in our optional research surveys, or other research activity such as an in person interview or panel. We do not collect this information when you register for the DTCE service. 

• Commercial information: This includes information about products or services considered, obtained or purchased.

• Internet or other electronic network activity information: We offer online services, so we collect CCPA personal information in this category, like your interactions with our service.

• Geolocation data: Our online services don’t collect precise geolocation data from GPS sensors. However, we do collect IP addresses from which we can determine your general location.

• Audio, electronic, visual, thermal, olfactory or similar information: We may collect photos, audio and/or video of you in certain circumstances. For example if you contact customer service, we may record the call (voice recording).

• Inferences: We have a recommendations system that strives to predict what you’ll be in the mood to learn when you log in. However, we do not have a list in our recommendation systems that attaches socio-demographic information to you like “soccer dad who likes tap dance lessons” or “financially savvy mom who craves modern dance” or “singleton high school grad who likes jazz dance sessions.” 

Uses of CCPA personal information

We use categories of CCPA personal information listed above for the purposes noted in the Use of Information section of our Privacy Statement. For ease of reference, we repeat that section below:

We use personal information to provide, analyze, administer, enhance and personalize our services and marketing efforts, to process your registration, your orders and your payments, and to communicate with you on these and other topics. For example, we use such information to: 

• determine your general geographic location, provide localized content, provide you with customized and personalized viewing recommendations for movies and TV shows we think will be of interest to you, determine your Internet service provider, and help us quickly and efficiently respond to inquiries and requests;

• to coordinate with Partners on making the DTCE service available to members and providing information to non members about the availability of the DTCE service, based on the specific relationship you have with the Partner; 

• prevent, detect and investigate potentially prohibited or illegal activities, including fraud, and to enforce our terms (such as determining free trial eligibility); 

• analyze and understand our audience, improve our service (including our user interface experiences) and optimize content selection, recommendation algorithms and delivery; 

• communicate with you concerning our service so that we can send you news about DTCE, details about new features and content available on DTCE, special offers, promotional announcements, consumer surveys, and to assist you with operational requests such as password reset requests. These communications may be by various methods, such as email, push notifications, text message, online messaging channels, and matched identifier communications (described below). Please see the “Your Choices” section of this Privacy Statement to learn how to set or change your communications preferences. 

Categories of CCPA personal information disclosed for a business purpose

We disclose the categories of CCPA personal information listed below for business purposes. (Please see the Disclosure of Information portion of our Privacy Statement for additional details that may be of interest to you.)

• Identifiers: We may disclose identifiers for business purposes with the following categories of third parties: Service Providers, Partners, an entity engaged in a business transfer, law enforcement, courts, governments and regulatory agencies.

• Characteristics of protected classifications under California or federal law: We may disclose these types of characteristics for business purposes with the following categories of third parties: Service Providers, an entity engaged in a business transfer/merger, law enforcement, courts, governments and regulatory agencies.

• Commercial information: We may disclose commercial information for business purposes with the following categories of third parties: Service Providers, Partners, an entity engaged in a business transfer/merger, law enforcement, courts, governments and regulatory agencies.

• Internet or other electronic network activity information: We may disclose these types of information for business purposes with the following categories of third parties: Service Providers, Partners, an entity engaged in a business transfer/merger, law enforcement, courts, governments and regulatory agencies.

• Geolocation data: We may disclose geolocation data for business purposes with the following categories of third parties: Service Providers, Partners, an entity engaged in a business transfer/merger, law enforcement, courts, governments and regulatory agencies.

• Audio, electronic, visual, thermal, olfactory or similar information: We may disclose these types of information for business purposes with the following categories of third parties: Service Providers, Partners, an entity engaged in a business transfer/merger, law enforcement, courts, governments and regulatory agencies.

• Inferences: We may disclose these types of data for business purposes with the following categories of third parties: an entity engaged in a business transfer/merger.

Sources of CCPA personal information

We explain our sources of information in the Collection of Information portion of our Privacy Statement. (Please see that section for more information that may be of interest to you.) For ease of reference, in regard to CCPA personal information these are:

• You (the consumer) when you provide us CCPA personal information directly, and when we collect it automatically based on your interactions with us (for example, through your computer or other DTCE capable device you use to access our service (such as gaming systems, smart TVs, mobile devices, set top boxes, and other streaming media devices);

• Partners (other companies with whom you have a relationship). These Partners might include (depending on what services you use): your TV or Internet service provider, or other streaming media device providers who make our service available on their device; mobile phone carriers or other companies who provide services to you and collect payment for the DTCE service for distribution to us; voice assistant platform providers who enable interaction with our service via voice commands; third party services that you are signed into that provide functions within DTCE games, such as multiplayer gameplay, leaderboards, and game saving options; and

• Other sources: service providers who support our business including security and payment service providers, and publicly-available sources, specifically, public posts on social media platforms; information about Internet Service Providers (ISPs) used by members to access DTCE through public databases associating IP addresses with ISPs.

Your rights under the CCPA

• You have the right to request that we disclose: what categories and specific pieces of CCPA personal information have been collected about you; the categories of sources from which CCPA personal information are collected; our business or commercial purpose for collecting, using, or disclosing CCPA personal information; the categories of third parties with whom we share CCPA personal information; the categories of CCPA personal information we have disclosed about you for a business purpose. We do not sell personal information.

• You have a right to receive a copy of the specific CCPA personal information we have collected about you.

• You have a right to deletion of your CCPA personal information, subject to exceptions under the CCPA.

• You have a right not to receive discriminatory treatment for exercising any of your CCPA rights. We will not discriminate against you based on your exercise of any of your CCPA rights. 

You can assert these rights only where we receive a verified request from you. For information on how to exercise your rights, please contact your DTCE representative.

If you are a consumer under the CCPA and wish to contact us through an authorized agent, the authorized agent can submit a request on your behalf at info@dancethecuttingedge.com along with a statement signed by you certifying that the agent is authorized to act on your behalf. In order to verify the request and your identity, we may ask you to verify your identity. 

If you do not own a DTCE account, we may not be able to respond to requests to exercise rights under CCPA, including the right to know or delete CCPA personal information. Because we only collect limited information about individuals without an account, we are unable to verify requests from non-account holders to the standard required by the CCPA.

     9. Questions and Concerns

If you have any questions or concerns regarding this Policy, please send an email to us at kimberly@dancethecuttingedge.com.