PRIVACY POLICY

Effective as of: February, 4 2019

This Privacy Policy will guide your rights and obligations in regards to data processing made on behalf of Violinspiration (thereinafter: the “Company” or the “Service”, where appropriate), a company formed in Rozenstraat 44, 6708EP Wageningen, Netherlands. This Privacy Policy will apply in cases that Violinspiration is the processor of the data you entrust its Services with.

This Privacy Policy further reflects the obligations taken on by Violinspiration under the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

Violinspiration, is the owner and operator of the Violin Immersion website (hereinafter referred to as: “Violin Immersion”, the “Website” or the “Service”, where appropriate), an online violin lessons website. Our Website may use cookies. On more information about the nature, usefulness and your preferences in regards to Cookies, please see the sections devoted to cookies and cookie usage in our Privacy Policy. This Privacy Policy shall not apply in instances where you use third-party Websites or Services that are not operated by the Operator of Violin Immersion.

Part of this Privacy Policy is our GDPR Compliance notice.

Your Personal Data is your explicit right. In the eyes of our Service, privacy is a priority. This Privacy Policy is written to inform you on:

The Website’s Privacy Practices when it comes to collecting, storing and sharing your Personal Data.
The Website’s methods of processing of your Personal Data, and the Website’s security measures implemented in order to protect your privacy
Your reserved rights in regards to the new Privacy regulations

„Violin Immersion“, „Website“, „Service“, „We“, „Us“, „Our“ means a Data Controller in the context of Regulation (EU) 2016/679, General Data Protection Regulation. This Privacy Policy shall be applicable in instances when our Website acts in the capacity of a Data Controller in the context of the GDPR
“You”, “Your” and “User” means a person, group or entity using the Violin Immersion in accordance to set forth in these Documents. References to “Data Subjects” mean references to Users whom are natural persons and are subject to processing of data by Violin Immersion.
“Personal Data” means any information relating to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
„Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction

The Services provided on the Violin Immersion are aimed to students and enthusiasts of any age. Our services provide an online violin lesson platform that is suited for anyone. In order for us to provide you with services, we might require some information from you. We advise you on getting acquainted with our Privacy Policy, as it contains references to your reserved rights in regards to your Personal Data.

1. Collection of Data

We collect certain data to provide you and improve the services of Violin Immersion. We further collect data to support advertising and marketing, and sometimes the location of users for the purposes of user authentication.
Some information will be collected directly from you, for example in instances when you are asked to fill out forms with your Personal Data (such as: name, email address, telephone number etc.) We might collect information that is usually about your device, browser or location in an automated manner. We may collect some information about you through third-party services which will be included in Appendix 1 to this Privacy Policy
Some data we may require from you are needed for your usage of our Services. For example, we may not be able to provide you with a User Account without you entering the compulsory registration forms. In order to provide you with our services, we may process certain data in connection to your personal profile (such as: your name, address, telephone number, e-mail address, gender, date of birth), data in connection to our services (data we have collected in order to provide you with our services), publication data (we may process information that you post for publication on our Website), enquiry, correspondence and notification data (any data you provide us with in any enquiry you submit to us, for example through our Customer Support email, or by your consent to opt in to subscription for newsletters or promotional emails), your transaction data (information in relation to transactions, without exclusion to purchases of goods and services, that include your contact details and transaction details). Please note that some of this information may not be compulsory when, for example, creating a User Account.
We may collect the data as described in subsection c) in the following instances:
– When you Register or Log into your User Account.
– When you edit your User Account Profile.
– When you contact our Customer Support service.
– When you share posts or comments in our Comment or Forum sections.

Please do not provide us information about third parties unless we explicitly request for you to do so.

2. How do we Use your Data

We process your data in accordance with these Terms of Service and Privacy Policy at all times. We do not store or retain data that is connected to your transactions, unless you have authorized us to do otherwise. We generally process your data in order to analyze the quality of our Services, to contact you or provide our services to you, more closely described in our Terms of Service.
We Use your Data for the following purposes:
– To provide you with the services you request and to collect payments.
– For marketing and advertising communication purposes sent directly to you with a prior subscription on your behalf.
– To run sweepstakes and contests, choose and deliver content and tailored advertising, for analytic purposes of usage of our services, to test changes and improvements of our services, to diagnose issues with our services and fix possible errors in our service.
– When it comes to other Users of our Website without an established User Account, we may collect aggregate or de-identified information about the user behavior and used devices. This Privacy Policy does not apply on instances when we use the de-identified and aggregated information for our personal analytic purposes.

The aforementioned aspects of Usage of your Data shall serve as a lawful basis in instances when the Violin Immersion is acting as a Data Controller in the context of European Data Protection law and regulations.

We collect and use data with your previous permission. Where we need the information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may have a legal obligation to collect or retain personal information or may need the personal information to protect your vital interests or those of another person. These instances may include the following:
– Usage of your information to create and maintain your User Account.
– Use the names and email addresses for marketing purposes to which you have subscribed to.
– Gather usage data to collect information on how to improve our services, which we will gather in relation to the legitimate interest of providing you with improved services, bug and error fixes.
When appropriate and effective, we may share some of your personal Data with third parties that perform certain services to us – for example, we may share your personal Data with our personal billing, marketing and technology services, or your transaction details with our authorized payment provider. When you subscribe to our newsletter, a third party mailing provider, MailerLite is used to push your newsletters to your inbox. This service’s privacy policy can be found at: https://www.mailerlite.com/legal/privacy-policy. All of these service providers have an established agreement with us and shall process the data in accordance to the best of privacy standards available. All of the data that is relating to your enquiries or financial transactions that are sent from the web browser to our server will be protected by using encryption technology. Personal Data including your name, contact information, cardholder data and possible stored passwords will always be stored in encrypted form.
All data relating to your financial transactions will be handled by our payment processors, such as PayPal and Stripe. We do not have access to your billing data, and all transactions handled by PayPal and Stripe will be provided by these Services. All payments made while using our services are secured by a SSL certificate with a 256 bit encryption. You can find the details of these services as well as their respective Privacy Documents in Appendix 1 of this Privacy Policy.
Generally, we store your date for a period not longer than is necessary for that purpose of storage. We will retain your personal data for a minimum period of 1 years following registration time, and for a maximum period of 2 years following registration time. In some cases we may retain your data for a longer period of time – namely when it is not possible for us to specify in advance the periods for which your personal data will be retained. We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are the subject, or in order to protect your vital interests or the vital interests of another third party.

3. Your Rights

Your personal data is your right, and our obligation is to be transparent about the way we may use it for the purposes of providing our services to us. We have compiled a list of your rights that you may exercise at any time. For more information, please send us a question on our Customer Support email, or inform yourself about your rights in-depth by reading the new privacy regulations. You may exercise the rights included below by sending a notice to us at any time:- Right to information – You have the right to check our legal bases for processing any of the aforementioned data and get acquainted with our Privacy Practices at any time by contacting our Customer Support email.- Right to Access – You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information (which includes details of the purpose of processing, categories of personal data concerned and the recipients of the personal data). Where there is no legal constraint, we will supply to you a copy of your personal data. The first copy will be provided free of charge, with the additional copies being subject to a reasonable fee.- Right to Rectification- You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.- Right to Erasure – In certain cases, you have the right to erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.- Right of Processing Restriction – In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.- Right to Object Processing – You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose. You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.- Right to Data Portability – To the extent that the legal basis for our processing of your Data is: – consent; – necessary for the performance of a contract to which you are the party, or to take steps at your request prior to entering into contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format, provided that there are no legal restrictions as foreseen by the privacy regulations.- Right to a Complaint to a Supervisory Authority – If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.- Right to Withdraw Consent at any Time – In cases in which the legal basis for our processing of your Data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

Please note that these rights are reserved in cases in which Violin Immersion regarded as a Data Controller in the context of European Privacy Protection laws and regulations, in instances when the Controller processes data of Data Subjects as defined in applicable European Privacy Protection regulations.

4. Your Choices

Regardless of your legal rights in accordance to applicable law provisions, you may manually choose to limit the collection and/or use of your Personal Data in the following manners:
– When filling out your User Profile that is meant to be shared with the general public (unless you opt for restricting the viewing audience in your Privacy Settings), your User Profile details are not compulsory. This means that your User Profile doesn’t have to contain any of the fields that are presented to you.- At any time, you may choose to opt out of any Marketing Messages that are sent to you by clicking the “Unsubscribe” link on any Marketing Message sent to your email. By following the “Unsubscribe” link to the specified newsletter(s) or marketing messages, you will no longer receive Marketing and Advertising messages that you opted out from.- You may manually select and limit any usage of Cookies. For more information on opting out of cookies, please see Section VI of this Privacy Policy.- You may manually opt out from targeted advertising and analytics platforms, such as Google AdWords, Google AdSense or Google Analytics, by using the following links: https://tools.google.com/dlpage/gaoptout, https://adssettings.google.com/authenticated.- If you are opting out from your mobile device, please see your individual mobile device model’s instruction on certain opt-outs. If you want to stop sharing any analytics or diagnosis data from your mobile device, please change your mobile device’s privacy settings.- If you want to restrict our access to your location information, you may choose to deny access to your location on your browser on your static computer device, or turn of location services on your mobile device(s).- You may opt to close your account at any time, at which time all data will be deleted from our Servers.

5. Cookie Policy

Cookies are small pieces of data that are stored on your static or mobile device’s website browser, or that may be stored locally on your device when you visit our Website. A cookie file contains an identifier, which is a string of letters and numbers that are sent back each time a browser requests a page from the server. Cookies are divided into session cookies (which expire at the end of the user session – i.e. at the time of closure of your device’s website browser), or persistent cookies (which expire at their designated expiry date, unless deleted prior to such date). Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
Why do we use cookies – We may use cookies in order to authenticate you, determine if you are logged into our website, maintain the state of your shopping cart as you navigate through Violin Immersion, personalize your user experience when logged in our Violin Immersion, to help us display relevant advertisements to you, analyze certain behaviors on our website, store your preferences in relation to the use of cookies, and finally use cookies as an element of security, in order to protect your user account from misuse.
Your cookie preferences – You can manage your cookie preferences manually, by sending us a request on our Customer Support email. Most browsers that are used by Users allow for User to refuse or accept cookie usage, or to delete the cookies from the browser memory.
Please note that with blocking cookies from your Website browser, or deleting clearing your cookies from your device may limit certain services that we provide – for example: if you delete or block the usage of your authentication cookies, you may have to sign in to your User Account manually every time you visit our Website.

6. PRIVACY COMPLIANCE SECTION
California Residents’ Privacy. European Economic Area and Switzerland Residents’ privacy. Cross-border transfers of data.

California Residents may ask for a list of Third Parties that have received information for direct marketing purposes for the last calendar year. The list will contain the type of information shared. This list will be provided to a California Resident without cost. We will not share your information with third parties for their own marketing purposes.
Our Servers are located outside of the European Economic Area and Switzerland. You are hereby informed that some of the information you may share with us will be transferred outside of Switzerland and the European Economic Area for processing. Our business premises and servers are located in the United States, which has been deemed by the European Commission as adequate for cross-border Data Transfer in accordance with the EU-US data shield policy, which may be found here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en. For more information on the European Commission’s adequacy report, please see: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.L_.2016.207.01.0001.01.ENG.
Recognizing that your privacy is important to you. The Violin Immersion employs technical security measures to protect your personal information. However, no transmission over the Internet can be guaranteed to be completely secure. Consequently, the Violin Immersion does not represent, warrant, covenant or guarantee the complete security of the personal information you provide to Violin Immersion. and does not accept any liability for personal information submitted to Violin Immersion which is misappropriated, inadvertently disclosed, misused, lost or altered despite the security measures which Violin Immersion employs or as a result of your or third parties’ use or misuse of personal information provided to or accessed through the Website. Security of your Personal Data is our top priority. We employ the aforementioned methods, but unfortunately, no method is so far 100% secure. As an entity and service bound by privacy protection laws, we will disclose any unauthorized breaches to our Data Servers, Website(s), or connected services within 72 hours after becoming aware of it.

7. PRIVACY COMPLIANCE SECTION. MINORS

This Website is not meant to be used by persons under the age of 18. We do not knowingly collect store or share information of minors. If you have any knowledge that a child without prior parental consent has been using our Services, please report this instance to our Customer Support Team at: support@violinspiration.com. We may, at the sole initiative, verify any User that may not fit our general eligibility criteria. State and International regulations may set the legal requirements differently. Further in this Section we state a few of them:
COPPA – We respect the statutory provisions of the Children’s Online Privacy Protection Act. Please note that the Federal Trade Commission, US Consumer protection Agency enforces the Children’s online Privacy Protection Act, which is to ensure the privacy and safety of children while utilizing internet-related services. Parents of minors are to review, delete, manage or refuse with whom their child’s information is shared by utilizing the “consent and opt-outs” subsection, or by means of direct contact towards the our Support Team. Under the COPPA act, we are not to be considered as a Service which markets to children. We do not, in any way, knowingly collect personal information from children under 13, except in particular situations where we are allowed to collect such information due to the exceptions to the valid parental consent as specified in the COPPA Act. We advise parents on keeping their static or mobile device access codes away from underaged children. Anonymized methods of information gathering (without limitation, to: cookies, clear pixel technology or behavioral tracking algorithms) is to be used towards users which have met the legal requirements and expressed strict consent to, and with full legal capacity and understanding of the possible effects of such consent.
CalOPPA – If you are a California Resident, this regulation may apply to you. If you are under the age of 18, and are a registered User, you may request from us to, at any time, delete any of your personally identifiable information, posts or stored files you have entrusted us with on your server. Please specify the information you want removed precisely, as a request of deletion of such information may not mean a complete or comprehensive removal of your information. For more information, please contact our Customer Support email at: support@violinspiration.com.
GDPR – If you are a Resident of the European Union or Switzerland, this regulation may apply to you. As a Company, we do not offer our products and services to minors. Our services are not intended for usage by persons under the age of 18 or age of majority in their respective jurisdiction. Under Art. 8 of the GDPR, minors are considered children under the age of 16. Any usage of our services by minors is conditioned on a Parent’s valid consent in the form of confirmation we will send to the Parent’s email address prior to commencing with any communication (commercial or otherwise) towards the minor.
Further information on minors – We do not market or offer any services to minors in your respective jurisdiction. If you believe that we have mistakenly sent any marketing or other communication to any minor, please report this instance throughout Customer Support email at: support@violinspiration.com.

8. Contact Us

Company name:	Violinspiration
KVK number:	78153980
Place of Business:	Rozenstraat 44, 6708EP Wageningen, Netherlands
Company email:	support@violinspiration.com

You may contact us in any manner you deem fit, as described below:

By Post to the Company’s Place of business, located at:

Violinspiration
Sportlaan 47, 6717LA Ede, Netherlands

Contacting our Customer Support email at: support@violinspiration.com

Your requests shall be assigned with a request order number and may take some time to process, depending on the queue of requests before you. We may take up to 5 or more business days to process your request.