Privacy Policy

Last Revised: March 2020

Lana Learn, Inc. (“Lana Learn,” “we,” or “us”) welcomes you to www.LanaLearn.com and any and all applications or mobile applications offered by Lana Learn, Inc (the “Site”). This Privacy Policy describes how Lana Learn collects and receives information about you through the Site, Services, and Content and through Lana Learn’s businesses, including offline. The Privacy Policy together with the Terms of Use govern your use of the Site and Lana Learn’s collection and use of your information.

Lana Learn is committed to protecting your privacy. We want to maintain a transparent relationship with you, and let you know how we collect and securely process any data you may provide us with. To this end, we have developed the current Privacy Policy, where you can gather all the relevant information and resolve any doubts that you may have in connection with the referred subject matters.

In the same way, we inform you that your data will be processed in accordance with the personal data protection laws currently in force; specifically, according to Washington State Technology Solutions Privacy & Data Protection guidelines to help ensure compliance with state laws, while seeking to protect personal information to the maximum extent possible.

1. Acceptance of Privacy Policy

Each time you access, use, or browse any Site or provide personal information to Lana Learn offline, you signify your acceptance of the then-current Privacy Policy. If you do not accept this Privacy Policy, you are not authorized to provide information to Lana Learn or use the Site and must discontinue use of the Site immediately.

Should the Privacy Policy be revised, Lana Learn will post the changes on the Site which will be effective immediately upon posting. Any material changes to the terms of the Privacy Policy will apply only to information collected thereafter, unless you provide consent. You can determine when the Privacy Policy was last revised by referring to the “Last Revised” legend at the top of this page.

If you provide your personal information to Lana Learn offline, the Privacy Policy applies to Lana Learn’s collection and use of your information. Lana Learn also may provide paper copies of the Privacy Policy when it collects information from you offline. In addition to this Privacy Policy, you agree that the provisions in the Terms of Use also govern Lana Learn’s collection and use of your information collected offline.

This Privacy Policy exists in English and other translations. In the event of inconsistencies between versions, the English version will prevail.

2. Types of Information We Collect

We may collect personal information from you including, without limitation, non-public information about you that helps Lana Learn identify you, such as first and last name, email address, password, preferences and interests, and other information that is not otherwise publicly available (collectively, “Personal Information”).

Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services.

We also may collect non-personal information about your use of the Site such as your IP address, usage statistics, browsing history, types of computers and/or mobile devices accessing the Site, Content or Services, type of computer operating system you use (e.g., Microsoft Windows or Mac OS), the type of browser you use (e.g., Firefox, Chrome, Internet Explorer), and the domain name of your internet service provider (collectively, “Traffic Data”).

3. How We Collect Information

We may collect personal information from you when you use the Site or register an account to access Content, Services or Activities provided on the Site or to request to receive emails or newsletters that may be offered on the Site or offline. Personal Information collected by Lana Learn may be stored and processed in the United States in accordance with the laws of the United States, or in other jurisdiction. By using the Site and submitting your personal information to Lana Learn online or offline, you expressly consent to the storage and processing of your personal information in the United States in accordance with the laws of the United States, or in other jurisdictions.

Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the United States or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

We may combine Personal Information we collect through our Site or offline with information that we obtain from our affiliates, suppliers, vendors, merchants, licensors, partners or sponsors, and other sources (e.g., offline records or publicly available information). We will treat the combined information as personal information.

Lana Learn may automatically receive and record non-personal information on our server logs from your browser as well as through other analysis of the Site. We also may collect information using cookies, web beacons or similar technologies, or through third parties using similar technologies.

A. Cookies

We use “cookies” to customize your experience with the Site, Content and Services and to store your information so you do not have to re-enter them each time you visit the Site or access the Content or Services. Cookies are small computer files that are transferred to your hard drive and contain information such as your username, user preferences, the web pages you’ve visited and the activities you’ve performed while using the Site, Content or Services. You may block or delete cookies from your hard drive; however, by disabling cookies, you may not have access to all of the Services or Content. Some of our business partners also use cookies to provide us with anonymous, aggregate data and information regarding our users. We do not have access or control over these cookies, and our Privacy Policy does not cover the use of third-party cookies. In order to opt out of a third party vendor’s use of cookies, visit the Network Advertising Initiative opt-out page.

B. Web Beacons

We or our third-party tracking utility company also use “web beacons” to collect information about your use of our Site, the websites of selected sponsors and advertisers, and our Content and Services. Web beacons are tiny graphic image files embedded in a web page or email that provide a presence on the web page or email and send back to its home server information from the user’s browser. The information collected by web beacons allows us to statistically monitor how many people are using our Site and Services, selected sponsors’ and advertisers’ websites and using our Services and for what purposes.

4. How We Use Your Information

We may use the information we collect:
To alert you to new features, terms, Content, Services, Activities, stores, restaurants or products.
To send emails or newsletters, and to provide you with personalized content in the newsletters.
To monitor and analyze information regarding your browsing and viewing preferences.
To analyze our users’ demographics and interests.
To administer Content, Services or Activities.
To process and respond to your inquiries.
To improve the Site.
For the purposes for which you provided the information.
To enforce the Terms of Use.

5. The Rights of Users

Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following:

Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

6. Retention Time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:

Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

7. Communications with You

You authorize Lana Learn to transmit email to you to respond to your communications and administer Services, Content or Activities. If you participate in any Services, Content or Activities, you agree that Lana Learn is authorized to contact you by to send information and documents to you by email or postal mail. Unsubscribe instructions are included in each promotional email from Lana Learn or you may sent an email requesting to opt-out of communications to info@lanalearn.com. Please note that such requests may take up to ten (10) days to become effective. You may not opt out of receiving communications regarding your dealings with Lana Learn or the Site, Content, Services or technical information about the Site.

8. Information Sharing with Third Parties

Lana Learn may disclose the information it collects about you: (i) to third parties to provide analytics for advertising purposes or to confirm or update information provided by you; (ii) to suppliers, vendors and others who help Lana Learn provide services to you, such as outsourcing one or more of the functions described in this Privacy Policy; (iii) to third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of Lana Learn’s business or operations (including without limitation in connection with bankruptcy or any similar proceedings); or (iv) as otherwise authorized by you.

We also may share your information in response to a subpoena, legal order or official request, when we believe you have acted in violation of the Terms, to investigate, prevent or take action regarding suspected illegal activities, fraud or potential threats, or exercise legal rights or defend against claims, when we believe that doing so may protect your safety or the safety of Lana Learn or others, or as otherwise permitted or required by law.

We also may use and share non-personally identifiable information with third parties. Additionally, we may take personally identifiable information and de-identify it and share it in a de-identified or aggregated form with advertisers, business partners, and/or third parties in order to analyze Site usage, perform services on our Site or others’ Site, improve our services, improve our user experience, or for similar purposes. We will not re-identify such data and we will ask our contracting parties to agree to keep the data in its de-identified form.

DISCLOSURES TO AGENTS AND SERVICE PROVIDERS We sometimes contract with other companies and individuals to perform functions or services on our behalf such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing and other services. They may have access to Personal Information needed to perform their functions but are restricted from using the Personal Information for purposes other than providing services for us or to us. Lana Learn requires that its agents and service providers that have access to Personal Information received from the EEA provide the same level of protection as required by the EU-U.S. Privacy Shield Principles.

We are responsible for ensuring that our agents, service providers and other third parties to whom we disclose your Personal Information process the information in a manner consistent with our obligations under the EU-U.S. Privacy Shield Principles.

9. Children

The Site is not directed toward children under 13 years of age nor does Lana Learn knowingly collect information from children under age 13 on the Site or offline. If you are under 13, you are not permitted to register for emails or newsletters or to otherwise submit any personally identifiable information to Lana Learn. If you provide information to Lana Learn through the Site, you represent that you are 13 years of age or older. If you are between 13 and 17 years of age, when you visit, browse, use, or submit personal information to the Site, you represent that you have the permission of a parent or guardian to do so and who agrees to these Terms on your behalf. If you are a parent or guardian and believe Lana Learn may have inadvertently collected personal information from your child, please notify Lana Learn immediately by sending a message detailing the basis of your belief and your request to info@lanalearn.com.

10. Protection of Personal Information

Lana Learn uses reasonable administrative, physical and electronic security measures to protect against the loss, misuse and alteration of personal information. No transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Lana Learn to intercept or access transmissions or private communications unlawfully. While we strive to protect personal information, neither Lana Learn nor our service providers can ensure or warrant the security of any information you transmit to us over the internet. Any such transmission is at your own risk.

11. Updating your Information

You are responsible for keeping your information current. You may update your information by contacting us at info@lanalearn.com or editing your account information. We will use reasonable efforts to process any change you make; provided, however, that requests to delete information are subject to Lana Learn’s internal reporting, processing and retention policies and all applicable legal obligations.

12. Notice of Privacy Rights of California Residents

We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice. Due to Lana Learn’s size/data collection, Lana Learn is not currently required to comply with the CCPA, but we do make an effort to do so.

If you are a California resident and have provided personal information to Lana Learn, you are entitled by law to request certain information regarding any disclosure that may have been made by Lana Learn to third parties of personal information for their direct marketing purposes. To make such a request, send a message to info@lanalearn.com.

The message should specify that you seek your “California Customer Choice Privacy Notice.” Please allow thirty (30) days for a response. Lana Learn is required to respond to only one request per customer each year, and is not required to respond to requests made by means other than through the above e-mail address.

We will not share your personal information with third parties for their direct marketing purposes if you request that we do not do so. You may make such a request by sending us a message at info@lanalearn.com.

When contacting us, please indicate your name, address, email address, and what personal information you do not want us to share with third parties for their direct marketing purposes. Please note that there is no charge for controlling the sharing of your personal information or for processing this request.

NON-DISCRIMINATION

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you goods or services.

Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

Provide you a different level or quality of goods or services.

Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. Lana Learn does not currently offer any incentive programs related to personal information.

13. Links

You may have the opportunity to follow links on the Site to other site that may be of interest to you. Lana Learn endeavors to only link to reputable organizations. Because other site may not be hosted or controlled by Lana Learn, we are not responsible for the privacy practices of those sites or the content provided thereon. Therefore, the privacy policies with respect to other site may differ from those applicable to the Site. We encourage you to review the privacy policies of each other site. This Privacy Policy only applies to information collected and maintained by Lana Learn.

14. Privacy Shield Policy

Lana Learn has adopted this Privacy Shield Policy (“Policy”) to establish and maintain an adequate level of Personal Data privacy protection. This Policy applies to the processing of Personal Data that Lana Learn obtains from Customers located in the European Union.

Lana Learn complies with the EU-U.S. Privacy Shield Framework and Swiss-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 and Switzerland to the United States. Lana Learn has certified that it adheres to the Privacy Shield Privacy Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, recourse, enforcement and liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Privacy Principles, the Privacy Shield Privacy Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov.

As further explained in the EU-U.S. Privacy Shield Principles, a binding arbitration option will also be made available to you in order to address residual complaints not resolved by any other means. The Federal Trade Commission (FTC) has jurisdiction over Lana Learn’s compliance with the Privacy Shield.

All Lana Learn employees who handle Personal Data from Europe are required to comply with the Principles stated in this Policy.

In compliance with the Privacy Shield Principles, Lana Learn commits 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 Lana Learn at info@lanalearn.com.

If you do not receive timely acknowledgment of your complaint, or if you cannot resolve your complaint directly with Lana Learn, you can contact the International Centre for Dispute Resolution, the international division of the American Arbitration Association (ICDR/AAA), by visiting its web site at http://go.adr.org/privacyshieldfiling.html. ICDR/AAA will investigate and assist you free of charge in resolving your complaint. Lana Learn has engaged the ICDR/AAA as an independent dispute resolution provider to address unresolved Privacy Shield complaints.

15. Questions?

If you have any questions or concerns regarding this Privacy Policy, please contact us at info@lanalearn.com