Last Updated: November 1, 2020

Equanimity Media, a d/b/a of Groove Inc. (“Equanimity Media”) is committed to protecting the privacy of our end users.  Equanimity Media knows that you care how information about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly. This Privacy Policy describes how we collect, use and share data, and what choices you have with respect to your data. We have updated this version of our Privacy Policy to reflect changes in data protection law.  This Privacy Policy applies to all Services that we own and operate, including the Services located at www.covidcompliant.ai and online services (our “Site”), as well as our other services, offerings, and other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with us (together with our Site, collectively referred to as our “Services”). If you do not agree with the data practices described in this Privacy Policy, you should not use our Services.  Please take a moment to familiarize yourself with our privacy practices and let us know if you have any questions.

We may modify this Privacy Policy from time to time, so we encourage you to review it frequently. If we make any material changes to the Privacy Policy, we will post a notice on our Services prior to such change taking effect.

WHAT PERSONAL INFORMATION ABOUT SITE VISITORS AND CUSTOMERS DOES Equanimity Media COLLECT?

The information we learn from customers helps us personalize and continually improve your general experience at Equanimity Media. Here are the types of information we gather:

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Services, including information:

• by which you may be personally identified, such as name, postal address, e-mail address, and telephone number (“personal information”);
• that is about you but individually does not identify you, such as country of resident; and/or
• about your internet connection, the equipment you use to access our Services and usage details.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the Site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
• From third parties, for example, our business partners.

Information You Provide to Us. The information we collect on or through our Services may include:

• Information that you provide by filling in forms on our Site. This includes information provided at the time of applying for our teacher training.  We may also ask you for information when you report a problem with our Site.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Details of transactions you carry out through our Site and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Site.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Site, or transmitted to other users of the Services or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Services with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

WHAT ABOUT INFORMATION COLLECTED AUTOMATICALLY?

Information We Collect Through Automatic Data Collection Technologies. As you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Site, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Site.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is statistical data and may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Services and to deliver a better and more personalized service.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Site.
• Flash Cookies. Certain features of our Site may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Site. Flash cookies are not managed by the same browser settings as are used for browser cookies.
• Web Beacons. Pages of our the Site and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Equanimity Media, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

DOES Equanimity Media SHARE THE INFORMATION IT RECEIVES?

Information about our customers is an important part of our business, and we are not in the business of selling it to others. We share customer information only as described in this Privacy Policy and with subsidiaries that either are subject to this Privacy Policy or follow practices at least as protective as those described in this Privacy Policy.

AFFILIATED BUSINESSES WE DO NOT CONTROL

We work closely with affiliated businesses. In some cases, these businesses sell offerings to you at Equanimity Media. In other cases, we operate stores, provide services, or sell product lines jointly with these businesses. You can tell when a third party is involved in your transactions, and we share customer information related to those transactions with that third party.

THIRD-PARTY SERVICE PROVIDERS

We employ other companies and individuals to perform functions on our behalf. Examples include fulfilling orders, delivering packages, sending postal mail and e-mail, removing repetitive information from customer lists, analyzing data, providing marketing assistance, providing search results and links (including paid listings and links), processing credit card payments, and providing customer service. They have access to personal information needed to perform their functions, but may not use it for other purposes.

These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

HOW DOES Equanimity Media USE YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Services, Site and its contents to you.
• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To provide you with notices about your account/subscription, including expiration and renewal notices.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Services or any products or services we offer or provide though it.
• To allow you to participate in interactive features on our Site.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data (the order form/registration form) or adjust your user preferences in your account profile.

PROMOTIONAL OFFERS

Sometimes we send offers to selected groups of Equanimity Media customers on behalf of other businesses. When we do this, we do not give that business your name and address. Before we send you any such offers, we will specifically ask you to approve the receipt of any such offers.  We will not send any offers to you if you have not specifically opt-in to receive the offers.

BUSINESS TRANSFERS

As we continue to develop our business, we might sell or buy businesses, subsidiaries, or business units. In such transactions, customer information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Policy (unless, of course, the customer consents otherwise). Also, in the unlikely event that Equanimity Media or substantially all of its assets are acquired, customer information will of course be one of the transferred assets.

PROTECTION OF Equanimity Media AND OTHERS

We release account and other personal information when we believe release is appropriate to comply with the law; enforce or apply our Terms of Use and other agreements; or protect the rights, property, or safety of Equanimity Media, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction. Obviously, however, this does not include selling, renting, sharing, or otherwise disclosing personally identifiable information from customers for commercial purposes in violation of the commitments set forth in this Privacy Policy.

WITH YOUR CONSENT

Other than as set out above, you will receive notice when information about you might go to third parties, and you will have an opportunity to choose not to share the information.

HOW SECURE IS INFORMATION ABOUT ME?

We work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input.

We reveal only the last four digits of your credit card numbers when confirming an order. We transmit the entire credit card number securely to the appropriate credit card company during order processing.

It is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign off when finished using a shared computer.

WHAT ABOUT THIRD-PARTY ADVERTISERS AND LINKS TO OTHER SERVICES?

Our site includes third-party advertising and links to other Services. We do not provide any personally identifiable customer information to these advertisers or third-party Services.  These third-party Services and advertisers, or Internet advertising companies working on their behalf, sometimes use technology to send (or “serve”) the advertisements that appear on our Services directly to your browser. They automatically receive your IP address when this happens. They may also use cookies, JavaScript, web beacons, and other technologies to measure the effectiveness of their ads and to personalize advertising content. We do not have access to or control over cookies or other features that they may use, and the information practices of these advertisers and third-party Services. are not covered by this Privacy Policy. Please contact them directly for more information about their privacy practices. In addition, the Network Advertising Initiative offers useful information about Internet advertising companies (also called “ad networks” or “network advertisers”), including information about how to opt-out of their information collection.

Equanimity Media also displays personalized third-party advertising based on personal information about customers, such as purchases on Equanimity Media, or visits to Equanimity Media’s associate’s Services. See below for more information about the personal information that we gather. Although Equanimity Media does not provide any personal information to advertisers, advertisers (including ad-serving companies) may assume that users who interact with or click on a personalized advertisement meet their criteria to personalize the ad.

WHICH INFORMATION CAN I ACCESS?

Equanimity Media gives you access to a broad range of information about your account and your interactions with Equanimity Media for the limited purpose of viewing and, in certain cases, updating that information. See below for some examples, the list of which will change as our Services evolves.

WHAT CHOICES DO I HAVE?

As discussed above, you can always choose not to provide information, even though it might be needed to make a purchase or to take advantage of such Equanimity Media features as your profile, and check out.

You can add or update certain information on pages such as those referenced in the “section listed above. When you update information, we usually keep a copy of the prior version for our records.

If you do not want to receive e-mail or other mail from us, please adjust your Member Account (If you do not want to receive Terms of Use and other legal notices from us, such as this Privacy Policy, those notices will still govern your use of Equanimity Media, and it is your responsibility to review them for changes.)

CHILDRENS’ ONLINE PRIVACY PROTECTION ACT COMPLIANCE

We are in compliance with the requirements of COPPA (Childrens’ Online Privacy Protection Act), we do not collect any information from anyone under 13 years of age. Our Services, products and services are all directed to people who are at least 13 years old or older.

RESEARCH AND EVALUATION

Equanimity Media is committed to ensuring that Equanimity Media meets the needs of the users. From time to time, we may undertake some research and evaluation activities with registered users to gain feedback and to better understand their needs.

The process may consist of asking users to complete short surveys whilst visiting the Equanimity Media Services, and all information collected will be maintained in accordance with relevant research standards and this Privacy Policy.

Registered users may opt not to participate, or withdraw from participating in these activities at any time. This will not affect their relationship with Equanimity Media or their use and access to Equanimity Media and other Equanimity Media programs.

The findings from these research and evaluation activities may be presented in reports, conference papers or published in journals or media releases, however users names will not be disclosed.

If Equanimity Media seeks registered users to assist in media releases or conference presentations, additional consent will be directly requested from any such user.

TERMS OF USE, NOTICES, AND REVISIONS

If you choose to visit Equanimity Media, your visit and any dispute over privacy is subject to this Privacy Policy and our Terms of Use including limitations on damages, resolution of disputes, and application of the law of the state of Delaware. If you have any concern about privacy at Equanimity Media, please Contact Us with a thorough description, and we will try to resolve it. Our business changes constantly, and our Privacy Policy and the Terms of Use will also change. We may e-mail periodic reminders of our notices and conditions, unless you have instructed us not to, but you should check our Services frequently to see recent changes. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account. We stand behind the promises we make, however, and will never materially change our policies and practices to make them less protective of customer information collected in the past without the consent of affected customers.

WHAT IF I LIVE OUTSIDE THE UNITED STATES?

Equanimity Media is headquartered in the United States. Your information, including personal information that we collect from you, may be transferred to, stored at and processed by us and our affiliates and other third parties outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in your jurisdiction. We will take all reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy.

References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European Union data protection legislation. We use the following safeguards if Equanimity Media transfers personal information originating from the European Union to other countries not deemed adequate under applicable data protection law:

Controller

Equanimity Media is the controller of your personal information for purposes of European data protection legislation.  See the Contact Information section below for contact details.

E.U.-U.S. Privacy Shield

Equanimity Media complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. Equanimity Media has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield Framework, visit https://www.privacyshield.gov/welcome.

We are responsible for the processing of personal data received under the Privacy Shield Framework and subsequent transfers to third parties acting as agents on our behalf. Equanimity Media complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions. With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Equanimity Media is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. We commit to cooperate with the EU data protection authorities and comply with advice given by such authorities with respect to any human resources data transferred from the EU in the context of the employment relationship. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

 

In compliance with the Privacy Shield Principles, we commit to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Equanimity Media’s privacy officer at support@equanimitymedia.com. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, you may contact our U.S.-based third-party dispute resolution provider (free of charge) at https://www.jamsadr.com/eu-us-privacy-shield.

Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

Legal bases for processing

We only use your personal information as permitted by law.  We are required to inform you of the legal bases of our processing of your personal information, which are described below.

·      Legal basis (e.g. through a contract you have with us), to provide Services you have requested from usl perform data processing necessary to complete the contract governing our provision of the Services or to take steps that you request prior to signing up for the Services, to communicate with you, to create aggregated or de-identified information, and to engage in compliance, fraud prevention and safety.

These processing activities constitute our legitimate interests.  We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

We may also process your date to comply with laws and our legal obligations.

Finally, we may also process your data with your consent, which you may withdraw at any time by emailing us at support@equanimitymedia.com.

Use for new purposes

We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it.  If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Your Rights

European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:

·      Opt-out. Stop sending you direct marketing communications. You may continue to receive service-related and other non-marketing emails.

·      Access.  Provide you with information about our processing of your personal information and give you access to your personal information.

·      Correct.  Update or correct inaccuracies in your personal information.

·      Delete.  Delete your personal information.

·      Transfer.  Transfer a machine-readable copy of your personal information to you or a third party of your choice.

·      Restrict.  Restrict the processing of your personal information.

·      Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights. 

You can submit these requests by email to at support@equanimitymedia.com or our postal address provided above.  We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us at support@equanimitymedia.com or submit a complaint to the data protection regulator in your jurisdiction.

Cross-Border Data Transfer

Whenever we transfer your personal information out of the EEA to countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on one of the following safeguards recognized by the European Commission as providing adequate protection for personal information, where required by EU data protection legislation:

·      Contracts approved by the European Commission which impose data protection obligations on the parties to the transfer.  For further details, see European Commission Model contracts for the transfer of personal information to third countries.

·      For transfers to third parties in the United States, ensuring they participate in the EU-US Privacy Shield Framework

Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.

CONTACT INFORMATION

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

support@equanimitymedia.com

+1 855 651 1116