This policy applies to information we collect:
- On this Site
- In email, text and other electronic messages between you and this Site.
It does not apply to information collected by:
- Us offline or through other means, including on any other website
- Any third party, including through any application or content that may link to or be accessible from our Site.
INTERNATIONAL USERS - CONSENT TO PROCESSING AND TRANSFER OF INFORMATION
The Service is operated and based in the United States, with our servers and offices headquartered in the United States. Please be aware that information you provide to us or that we obtain as a result of your use of the Service may be processed and transferred to, and be subject to the laws of, the United States. The privacy and data protection laws in the United States may not be equivalent to privacy and data protection laws in your country of residence. By using the Service, or by providing us with any information about your preferences or about you, including information that could reasonably be used to contact you or to identify you personally, such as your name, e-mail address, telephone number or home address you consent to the collection, transfer, storage, and processing of any and all such information to and within the United States and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to those in the country where you reside and/or are a citizen.
INFORMATION WE COLLECT
Information You Provide to Us
In connection with the Service, the Company may collect information that can identify you. The type of personal information may vary depending upon your membership type. The information for general members may include a username, your name and your email address. The information we collect from teachers may include a username, your name, your email address, a short biography, various social media account handles, a general geographic location, information concerning your yoga practice and experience, and other similar information (“Personal Information”). We may also collect information about you that does not specifically identify you, such as gender, but if Setu associates it with you as a specific and identifiable person, Setu treats it as Personal Information.
We collect this Personal Information only when it is voluntarily submitted to us. For example, this may be when you fill out forms on the Site, create a profile, subscribe to our Services, complete or initiate a transaction on the Site, post material on the community board, request further services, or report a problem with the Site.
Information We Collect Automatically
Whenever you visit or interact with the Service, Setu, as well as any third-party vendors and/or service providers, may use a variety of technologies that automatically or passively collect information about how the Service is accessed and used (“Usage Information“). Usage Information may include, in part, browser type, operating system, device type, an estimate of your geographic location associated with your IP address, the location of your mobile device, the page served, the time, referring URLs and other information normally transmitted in HTTP requests. This statistical data provides us with information about the use of the Service, such as how many visitors visit a specific page on which the Service is installed, how long they stay on that page, the type of content on that page, which hyperlinks, if any, they “click” on and how they generally engage with that page. Usage Information is generally non-identifying, but if Setu associates it with you as a specific and identifiable person, Setu treats it as Personal Information.
IP Addresses and Device Identifiers
We also automatically collect the internet protocol (“IP“) address or other unique identifier (“Device Identifier“) for each computer, mobile device, technology or other device (collectively, “Device“) you use to access the Service. A Device Identifier is a number that is automatically assigned to your Device when you access a web site or its servers, and our computers identify each Device by its Device Identifier. An IP Address is a number assigned to your computer by your Internet service provider so you can access the Internet. Generally, an IP address changes each time you connect to the Internet (it is a “dynamic” address). Note, however, that if you have a broadband connection, depending on your individual circumstance, it is possible that your IP Address that we collect, or even perhaps a cookie we use, may contain information that could be deemed identifiable. This is because with some broadband connections your IP Address doesn’t change (it is “static”) and could be associated with your personal computer. We use your IP address to report aggregate information on use and to help improve the website.
A cookie is a small string of data sent by the Service that is stored in your Device and provided back to the Service each time you interact with the Service. Cookies do not convey Personal Information about you; they provide anonymous information to us regarding how you use the Service. We may use session cookies, which are temporary cookies that disappear after you close your browser and/or persistent cookies, which remain on your hard drive after you close your browser and are reloaded when you open a new browser session. In general, cookies can make it so that you do not need to log-in again to the Service once you have already done so, they help us and our partners better understand users’ interests in order to make improvements, they allow us to show you specific content recommendations that we think will be of particular interest to you, and they can make the Service load faster and more enjoyable to use.
As is true of most web sites, we and our third-party tracking-utility partners gather certain information automatically and store it in log files. This information includes IP addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp and clickstream data.
We use this information, which does not identify individual users, to analyze trends, to administer the Site and Service, to track users’ movements around the Sites and Service and to gather demographic information about our user base as a whole.
Web Beacon / Pixel tags
A Web Beacon, also called a single-pixel (1x1), clear GIF, or pixel tag, is a transparent image embedded in a webpage or HTML-based e-mail that allows us to collect web log information. Web log information is gathered when you visit one of our websites by the computer that hosts our website (called a “webserver”). We may also include web beacons in e-mail messages in order to determine whether messages have been opened. This information may include the time and date of a page view, the webpage where the beacon is placed, the pages you visited, the website you came from, the type of browser you are using (e.g., Chrome), the type of operating system you are using (e.g., Windows 10), and the domain name and address of your Internet service provider. No Personal Information is detected by web beacons, but they can help us track online usage patterns of our users and gauge the effectiveness of our activities anonymously by, among other things, enabling us to see whether particular webpages are viewed or e-mails are opened by recipients. While you may not decline web beacons, you may render some web beacons unusable by rejecting their associated cookies. However, if you disable the cookies associated with a beacon, some services may not function properly.
We may also use other kinds of local storage, such as “flash cookies,” authentication tokens, and HTML5 local storage. Like cookies, these technologies are stored on your computer, albeit in different parts of your device, and perform similar functions. They can also be used to store certain information about your preferences. Your Internet browser may allow you to disable HTML5 or delete information contained in HTML5 local storage by changing your browser setting. Please note that disabling these technologies may interfere with the performance and features of the Service.
Information Collected by Third Parties
We use third-party analytics services to analyze various data. We currently use Google Analytics, a service which transmits website traffic data to Google servers in the United States. Google Analytics does not identify users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand website traffic and webpage usage. You can find out more about the information Google collects, and controlling the information collected by Google at https://policies.google.com/technologies/partner-sites. You can find more about the cookies used by Google at https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage.
Third Party Content and Applications
HOW WE USE THE INFORMATION WE COLLECT
Setu uses the information we collect about and from you for a variety of business purposes. Generally, the information we collect about you, your interests, and your activities helps us to improve the Service and deliver a better and more personalized service to you by enabling us to customize the Service according to your individual interests, estimate our audience size and usage patterns and speed up your searches. For example, we may use information collected from you in any one or more of the following ways:
- To create and register your account.
- To recognize you upon your return to the Site.
- To customize your user experience and understand your preferences.
- To respond to requests you may make of us.
- To communicate with you, including to (i) respond to customer support inquiries, and (ii) keep you informed of events, (iii) notify you regarding changes in your account or membership expiration or renewal.
- To allow you to participate in interactive features on the Site.
- To notify you regarding any changes to our Site or Services.
- To better understand your needs and how we can improve our websites, products and services.
- To enable user communications, such as the community board.
- To prevent fraud or potentially illegal activities, and enforce our Terms of Service
- To resolve disputes, collect fees, and troubleshoot problems.
- To analyze our audience, trends and user traffic and gather statistical information.
- To analyze our system functionality.
- To fulfil any other purpose for which you provide the information.
- In any other way we may describe when you provide the information.
We may also send promotional e-mail messages (“Promotional Communications”) directly or in partnership with parties other than the Company. Promotional Communications may be about our own or third party goods or services that may be of interest to you. You are able to opt of these communications, as noted in the Promotional Communications section below.
HOW WE SHARE INFORMATION
Services On Our Behalf
In order to carry out your requests, to make various features, services and materials available to you through the Service, to analyze and understand how our Service is performing, and to respond to your inquiries, in certain instances we may share your Usage Information or Personal Information with third parties that perform functions on our behalf (or on behalf of our partners). These third parties include companies or individuals to assist us in the day-to-day operations of our services, send e-mails on our behalf, to host or operate the Service, to analyze data or provide customer service. These agents, contractors or partners are restricted from using this data in any way other than to provide services for the Company, or services for the collaboration in which they and the Company are engaged (for example, some of our products are developed and marketed through joint agreements with other companies). These parties may set and access their own cookies, pixel tags and similar technologies on your Device and they may otherwise collect or have access to information about you, including Usage Information. We may also use third party redirects, which will redirect you through a third party server before redirecting to the final landing page. On this redirect, the third party may place its own cookies, pixel tags and similar technologies on your device (e.g., for purposes of retargeting) and collect or have access to information about you, including Usage Information.
Business Transfers or Financing
We may use, share and transfer Personal Information and Usage Information, and any other information that we have collected about the users of the Service as an asset in connection with a proposed or actual merger or sale (including any transfers made as part of an insolvency or bankruptcy proceeding), or purchase of another entity, involving all or part of our business or as part of a corporate reorganization, stock sale or other change in control, or in connection with the contemplated or actual financing, insuring, sale, assignment or other disposal of all or part of our business or assets, including for the purposes of determining whether to proceed or continue with such transaction or business relationship or fulfilling any records or other reporting requirements to such parties. Your Personal Information, Usage Information any other information that we have collected about the users of the Service may also be shared with our subsidiaries or corporate affiliates for internal reasons, primarily for business and operational purposes.
Setu may transfer and disclose information, including your Personal Information, Usage Information and Device Identifier, to third parties to comply with certain legal obligations when we believe in good faith that the law requires it; which may include, at the request of governmental authorities conducting an investigation; to verify, enforce or applicable terms or other applicable policies; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of Setu, our customers or others. This may also include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
CHILDREN AND MINORS
The Service is not directed to children under 13 years of age. We do not knowingly collect Personal Information from children under 13. If you are under 13, do not provide any information on the Service or on or through any of its features or register on the Service or otherwise provide any information about yourself to us. We are not responsible for independently verifying the age of users. Should you, as a user’s parent or legal guardian, become aware that a user who is under the age of 13 has provided us with Personal Information, please notify us immediately by e-mail at firstname.lastname@example.org or by mail at Setu LLC, 5931 Catalpa Ave, Ridgewood, NY 11385. If we become aware that we have unknowingly collected Personal Information from a child under the age of 13, we will make reasonable efforts to delete such information from our records.
In addition to the above we require that anyone who purchases a paid subscription on the Site or makes any purchases initiated through the Site be at least 18 years old.
HOW WE STORE, SECURE, RETAIN AND DELETE YOUR INFORMATION
Setu takes reasonable administrative and electronic measures designed to safeguard and protect your Personal Information from accidental loss or unauthorized access, disclosure, or use. This may include using technologies such as Secure Sockets Layer (SSL) and may include one or more firewalls designed to block access from outside our network. Some of these protections may only be available to the extent that you are using an up to date and supported browser. Information we collect may be stored or processed on computers in any country where we do business.
ALTHOUGH SETU STRIVES TO PROTECT YOUR PERSONAL INFORMATION AND PRIVACY, NO SECURITY METHOD OR FIREWALL CAN BE GUARANTEED TO PROTECT INFORMATION FROM HACKERS OR HUMAN ERROR. ANY TRANSMISSION OF ANY PERSONAL INFORMATION IS AT YOUR OWN RISK. WE EXPRESSLY DISCLAIM RESPONSIBILITY AND/OR LIABILITY FOR THE LOSS, THEFT, DESTRUCTION OR INADVERTENT DISCLOSURE OF YOUR PERSONAL INFORMATION.
In the unfortunate event that your Personal Information is compromised, we may notify you by e-mail at the last e-mail address you have provided to us, in a reasonable time under the circumstances and as required under law. Delays in notification may occur while we take necessary measures to determine the scope of the breach and restore reasonable integrity to the system, as well as at the legitimate request of law enforcement should it be determined that such notification would impede a government investigation.
In accordance with our routine record keeping, we may delete certain records that contain Personal Information or Usage Information. We are under no obligation to store such Personal Information or Usage Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Personal Information or Usage Information. In addition, you should be aware that it is not always possible to completely remove or delete all of your information from our databases without some residual data because of backups and other reasons. Setu may also retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Where we have given you (or where you have chosen) a password that enables you to access certain features of the Service, you are responsible for keeping this password confidential. Do not share this password with anyone.
HOW TO ACCESS AND CONTROL YOUR INFORMATION
You have certain choices available to you when it comes to your information. Below is a summary of those choices, how to exercise them and any limitations. We will respond to requests about this within a reasonable timeframe.
You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. Below, we describe the tools and processes for making these requests. You can exercise some of the choices by logging into the Services and using settings available within the Services or your account. For all other requests, you may contact us as provided in the Contact Us section below to request assistance.
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 are permitted by law or have compelling legitimate interests to keep. Where you have asked us to share data with third parties, you will need to contact those third-party service providers directly to have your information deleted or otherwise restricted. 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.
- Access and update your information: Our Service and related documentation gives you the ability to access and update certain information about you from within the Service. For example, you can access your profile information from your account. You can update your profile information within your profile settings and modify content that contains information about you using the editing tools associated with that content. You can also send us an email request at email@example.com with a request to update your account.
- Delete your information: Our Service and related documentation gives you the ability to delete certain information about you from within the Service. We cannot delete all of the information about you without deleting your user account. You can also send us an email request at firstname.lastname@example.org with a request to delete your account. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations. Note that if you delete your User Contributions from the Site, copies of your User Contributions may remain viewable in cached or archived pages, or might have been copied or stored by other users of the Site.
- Request that we stop using your information: In some cases, you may ask us to stop accessing, storing, using and otherwise processing your information where you believe we don't have the appropriate rights to do so. For example, if you believe an account was created for you without your permission or you are no longer an active user, you can request that we delete your account as provided in this policy. Where you gave us consent to use your information for a limited purpose, you can contact us to withdraw that consent, but this will not affect any processing that has already taken place at the time. When you make such requests, we may need time to investigate and facilitate your request. If there is a delay or dispute as to whether we have the right to continue using your information, we will restrict any further use of your information until the request is honored or the dispute is resolved. You can also opt-out of our use of your information for marketing purposes by contacting us, as provided below.
You always have the choice to stop receiving Promotional Communications. If you do not want us to use your information in this way, you can so indicate in the form you fill out when you provide the information. Also, when you receive Promotional Communications from us you will have the opportunity to “opt out” by following the unsubscribe instructions provided in the Promotional Communication you receive, such as by return email. Please note that despite your indicated e-mail preferences, we may still send you administrative messages regarding the Company services, including, for example, administrative confirmations, and notices of updates to our policies.
OTHER IMPORTANT PRIVACY AND DATA INFORMATION
Third Parties and Other Sites
The Service may also contain links to other sites that we do not own or operate. For example, as of the Effective Date, we use Eventbrite for booking events. These sites may request you to provide information in order to complete your purchase or booking. We do not control, recommend or endorse and are not responsible for these sites or their privacy policies or practices. These other web sites may send their own cookies to your Device, they may independently collect data or solicit Personal Information and may or may not have their own published privacy policies. The policies and procedures we described here do not apply to those sites. We suggest contacting those sites directly for information on their privacy, security, data collection, and distribution policies.
Sweepstakes and Contests
“Do Not Track”
Do Not Track is a voluntary program among Internet advertisers that is intended to give users the ability to opt-out of behavioral targeting and advertising. There are a few ways in which your computer may send a “do not track” signal to certain websites and online services you visit. Setu and many or all of its third-party services that collect analytics do not currently honor Do Not Track settings. If you do not agree with Setu’s policy not to honor Do Not Track, your only remedy is to immediately stop using the Service.
Last Modified: [June 21, 2019]