Effective Date: August 23, 2018
Commune Media, Inc. (“Commune”) understands and respects our users’ need for privacy. This Privacy Notice (“Notice”) describes the types of information we collect, the purposes for which it is used, and the choices you have with respect to its use.
Commune creates digital video courses with the world’s leading teachers across yoga and fitness, mindfulness, food and health, sustainability, and civic engagement. Commune believes personal wellness is inextricably tied to societal well-being. Our courses are designed to help people bring their best selves into the world around them. The course programs, (the “Service” or “Services”) can be accessed via our digital video on-demand platform website (including onecommune.com and commune.mn.co, the “Site” or “Sites”). For more information about our Services, check out the “Community” section on our website.
Who You Are
This Notice applies to users of the Commune Service, paying Commune customers, and Commune website visitors (“Users”). We encourage you to read this Notice in full to understand our privacy practices before using our Services.
Information We Receive From You
We collect the following information through your use of our Services, and otherwise with your consent. In some cases, we receive information directly from you. For example, when you sign up for the Commune mailing list, we collect your first name and email address. The types of information that we collect include:
- Information about you and your Commune Account – Name and email address. This information is collected automatically, or you provide this information to us directly when you sign up for free programs. Name, email address, user ID, username and password. This information is collected automatically, or you provide this information to us directly when you register for an account and sign up for paid programs.
- Order and transaction information – Name, billing address, shipping address, payment information (including credit card numbers), email address, and phone number. This information is collected automatically, or you provide this information to us directly when you make a purchase or attempt to make a purchase through the Site.
- Device information – IP address, time zone, device type, operating system, manufacturer, model, and model number, and unique device identifiers such as your user name and password. We collect this information automatically when you use our Services.
- Usage analytics – Browser type, and usage details, such as time, frequency, and use pattern. In some cases, we analyze information on specific end users such as the amount of time spent on the platform. In others we look at data in the aggregate. We use this information to optimize our Services. We collect this information automatically when you use our Services.
- Social media information – Social posts and user generated content, such as user photos, other images you share with us, or screenshots and photos taken during use of our Services. You provide this information to us directly when you post in our community area. In other cases, we collect information about your social media interactions automatically. For example, we may receive information from social media sites when you choose to participate in social media-sponsored activities and offerings we provide via social media plug-ins on our website. In other cases, when you connect with Commune’s accounts on third party social networking sites, we may also collect information about your social networking accounts, for example, your name, user name, or handle.
To learn about your information collection choices and to opt-out of data collection, see the “Your Choices” section below.
Information We Receive from Other Sources
- Commune marketing partners – Marketing partners of our Services may provide information about you when you submit content to them through their services. For example, you may be mentioned in a troubleshooting ticket opened by someone else. We will only use this information for the purpose of providing our Services.
- Other partners – We receive information from other partners to help us find potential customers and enhance our Services with useful information. For example, information provided by our partners allows us to provide optimization services, such as when we receive data analytics from Google Analytics, or Facebook Insights.
How We Use, Share, and Disclose Information
We use collected information to:
- Communicate with you – We may contact you to respond to your inquiries, requests, and/or send important notices either via email. This includes, for example, sending order confirmations and receipts, technical notices, service updates, administrative messages, and providing you with updates about our Services and new features. See “Your Choices” below to learn how to manage your communication preferences.
- Provide customer support – We use your Commune usage information to resolve support issues that may arise through your use of our Services. Commune employees are prohibited from viewing the content of data you import into your Commune account, except when necessary to resolve your support issues. Access is limited to the data required to resolve your support issues.
- Deliver and improve our Services – We use your information to deliver and analyze how you use our Services, develop new products and services, and improve functionality, quality, and user experience. This includes using aggregated, anonymized data to improve our Services. For example, we may use personal data in the aggregate to provide customer support or for research and development purposes. For more information see “Browser and usage information” in the “Information We Receive From You” section above. In other cases, we collect location information such as city, state, country, and ZIP code to facilitate order processing and order shipping for physical products.
- Market our Services – We use your information to market our Services. For example, we may send you an email notification about new product features. Additionally, we may use pseudonymized personal information collected on our website to better tailor marketing or website content, including to run or optimize our service, or for other purposes, such as internal research. For example, we may use market segmentation tactics for targeting purposes, to advertise products and services. To learn more about how we track and use your information, see our Cookie Notice here
- Store data – We store data on servers hosted by NewKajabi.com. We use appropriate technical, administrative, and physical measures to secure your data during storage.
We share information about you with third parties only in the manner described below:
- Marketing and advertising – We do not sellinformation about you to advertisers or other third parties. We do however, share information such as your name and email address with our marketing partners. For example, we may send you an email notification about new product features. In other cases, we may share names and email addresses with our marketing partners when you sign up for a program which may include use of their products, such as a yoga matt or yoga blocks. If this changes we will obtain your consent first.
- Mergers and acquisitions – If your personal information is transferred to a party unaffiliated with Commune as part of merger, acquisition, or sale of all or a portion of our assets, we will provide you with notice prior to transferring your personal information to the new entity. Notice will be provided directly through our Services.
- Legal purposes – We disclose your information when we believe that disclosure is (1) reasonably necessary to comply with any applicable law, regulation, subpoena, legal process, or enforceable governmental request; (2) necessary to enforce the provisions of the Notice; (3) required to enforce our Terms of Service, including investigation of potential violations; or (4) necessary to protect against harm to the rights, property, or safety of Commune, our users, or the public as required or permitted by law.
- External processing and Subprocessors – We provide your information to other third parties to help us with our business activities, products, and services. These companies are authorized to use your information only as necessary to provide these services or perform them on our behalf. For example, we may share your IP address with our e-commerce partner to prevent fraud.
We use the following sub-processors to operate our Services. This list was last updated on August 16, 2018.
Legal Bases for Processing (for EEA users)
If you are an individual from the European Economic Area (“EEA”), we collect and process your personal data only where we have legal basis for doing so under applicable EU laws. The legal basis depends on the Services you use and how you use them. This means we collect and use your personal data only:
- To fulfill our contractual obligations to you;
- To operate our business, including to improve and develop our services, for fraud prevention purposes, improve user experience, or other legitimate interest; and/or
- As otherwise in compliance with law.
If you have any questions about the legal basis for processing, please refer to the “Your Rights” section below or contact us at the address listed in the “Contact Us” section.
We do not respond to web browser “Do-Not-Track” signals.
Behavioral Advertising and Targeted Ads
We do not serve targeted advertisements in our Services at this time. However, you may see targeted ads from us on other websites based on your browsing history or other online activities. We do not participate in the Network Advertising Initiative (NAI), Digital Advertising Alliance (DAA) or TrustArc opt-out programs.
For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising by using the links below:
- Facebook: https://www.facebook.com/settings/?tab=ads
- Google: https://www.google.com/settings/ads/anonymous
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
Where appropriate or legally required, we will describe how we use personal information, so you can make choices about how your data is used. You can notify us of your preferences during the information collection process and change your selection at any time by contacting us directly.
- Geolocation – We collect your geographic location when you use our Services. You can restrict our access to and collection of your location information by disabling location-sharing on your browser.
- Marketing emails – You can choose to stop receiving marketing emails by following the unsubscribe instructions included in these emails, or by using the email address listed in the “Contact Us” section below. If you opt out of receiving marketing emails, we may still send you non-promotional emails, such as emails about your Commune account.
- Account information – You can stop Commune from collecting information through your Commune account by contacting us and requesting deactivation of your account using the email address listed in the “Contact Us” section below.
You have certain rights in connection with the personal information we obtain about you. To update your preferences, correct your information, limit the communications you receive from us, or submit a request to exercise your rights, please contact us as specified in the “Contact Us” section.
As required by law, you have the right to:
- Request access to certain personal information we maintain about you;
- Request that we update, correct, amend, erase or restrict certain personal information; and
- Exercise your right to data portability.
For all requests, you can contact us as provided in the “Contact Us” section below to request assistance.
In some circumstances you can withdraw consent you previously provided to us or object to the processing of your personal information, and we will apply your preferences moving forward.
To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. We may also decline your access request, but in the event we do, we will provide an explanation for our decision. Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we or your administrator are permitted by law or have compelling legitimate interests to keep. If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed.
Our Services are not directed to children under the age of 13, and we do not knowingly collect information from children under the age of 13.
How Long We Retain Information
How long we keep information we collect about you depends on the type of information, as described below. We will either delete or anonymize your information or, if this is not possible (for example, the information is stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.
- Information about you and your Commune Account – We retain your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate our Services. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Services. Where we retain information for the improvement and development of our Services, we take steps to eliminate information that directly identifies you. If our Services are made available to you through our partners, we retain your information as long as required by the Partner. For more information, see "Information We Receive from Other Sources" above.
- Order and transaction information – When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information.
- Marketing information – If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services, such as when you last opened an email from us or ceased using your Commune account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date the information was created.
We use reasonable and appropriate physical, technical, and administrative safeguards to protect your information from unauthorized use, access, loss, misuse, alteration, or destruction. We also require that third party service providers acting on our behalf or with whom we share your information also provide appropriate security measures in accordance with industry standards. Notwithstanding our security safeguards, it is impossible to guarantee absolute security in all situations. If you have any questions about security of our Services, please contact us using the email address listed in the “Contact Us” section below.
Changes to this Privacy Notice
We periodically update this Notice to describe new features, products, or services, and how those changes affect our use of your information. If we make material changes to this Notice, we will provide notification through our services and/or notify you directly. We encourage you to review this Notice for updates each time you use our Services.
Third Party Services, Applications, and Websites
Certain third party services, websites, or applications you use, or navigate to from our Services may have separate user terms and privacy policies that are independent of this Notice. This includes, for example, websites owned and operated by our customers or partners. We are not responsible for the privacy practices of these third party services or applications.
If you have questions about this Notice or our information handling practices, please contact us at email@example.com or write to us at:
Commune Media, Inc.
PO Box 93921
Los Angeles, CA 90093