The Dawson Academy Privacy Policy

The Dawson Academy (“TDA,” “we” or “us”, “our” and terms of similar meaning) is committed to protecting your privacy. This privacy policy (“Privacy Policy”) governs the website(s) located

at TheDawsonAcademy.com, TheDawsonAcademy.uk, and www.DawsonWizard.com (the “Site”) and our related online products and services, including our applications (collectively, the “Services”). It describes the information that we collect from users of our Site and Services (“you” and “your”) as part of the normal operation of our Site, and how we use and disclose this information. We created this Privacy Policy to give you confidence as you make use of the Site and the Services and to demonstrate our commitment to fair information practices and the protection of user privacy. Your use of the Site and the Services is governed by this Privacy Policy, as well as our Software as a Service agreement, which is incorporated herein by reference.

By accepting the Privacy Policy in registration or by visiting and using the Site, you expressly consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to our Software as a Service agreement, found at www.dawsonwizard.com/SaaS.

We may revise this Privacy Policy from time to time. We will alert you when any changes are made to this Privacy Policy by displaying a prominent notice on the Site, or by sending you an email notification. While we will notify you of any material changes to this Privacy Policy, we encourage you to review this Privacy Policy periodically.

What Information Do We Collect?

Our primary purpose in collecting personal information from you is to provide you with a safe, smooth, efficient, and customized experience. This allows us to provide services and features that most likely meet your needs, and to customize our service to make your experience safer and easier. We only collect personal information about you that we consider necessary for achieving this purpose.

“Personal Information”

This refers to any information that you voluntarily submit to us and that identifies you personally, including contact information, such as your name, e-mail address, company name, address, phone number, and other information about yourself or your business. Personal Information can also include information about any transactions, both free and paid, that you enter into on the Websites, and information about you that is available on the internet, such as from Facebook, LinkedIn, Twitter and Google, or publicly available information that we acquire from service providers.

Personal Information also includes Navigational Information or Payment Information where such information can directly or indirectly identify an individual. Navigational information refers to information about your computer and your visits to this website such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed. Please see the “Navigation Information” section below. We collect and process payment information from you when you purchase something on our websites, including credit card numbers and billing information, using third party PCI-compliant service providers. Except for this, we do not collect sensitive information from you.

Log Files

When you use our services or view content provided by us, we automatically collect information about your computer hardware and software. This information can include your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, access times and referring website addresses. This information is used by The

Dawson Academy for the operation of our services, to maintain quality, and to provide general statistics regarding use of our websites. For these purposes, we do link this automatically-collected data to Personal Information such as name, email address, address, and phone number.

Information About Children

The Websites are not intended for or targeted at children under 16, and we do not knowingly or intentionally collect information about children under 16. If you believe that we have collected information about a child under 16, please contact us at info@thedawsonacademy.com, so that we may delete the information.

How We Use Your Information

We use personal information in the file we maintain about you, and other information we obtain from your current and past activities on the Site and using our Software, to provide to you the services offered by the Site; resolve service disputes; troubleshoot problems; measure consumer interest in our products and services, inform you about online and offline offers, products, services, events and updates; deliver information to you that, in some cases, is relevant to your interests, such as product news; customize your experience; detect and protect us against error, fraud and other criminal activity; enforce our Software as a Service agreement; provide you with system or administrative messages, and as otherwise described to you at the time of collection.

We may also use personal information about you to improve our marketing and promotional efforts, to analyze Site usage, to improve our content and product offerings, and to customize the Site’s content, layout, and services. These uses improve the Site and better tailor it to meet your needs, so as to provide you with a smooth, efficient, safe and customized experience while using the Site.

Please see our Software as a Service agreement for information on our management of account information when you terminate your account with us.

Our Disclosure of Your Information

We will never sell your Personal Information to any third party. We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, we do not transfer your Personal Information to the third party.

The following describes some of the ways that your information may be disclosed in the normal scope of business to provide our services:

  • Anonymized Aggregated Data. We aggregate and anonymize data and use and disclose such information for a variety of However, in these situations, we do not disclose any information that could be used to identify you personally.
  • Public Areas of the All of your activities in the public areas of the Site will be identifiable to your Registered User ID if applicable, and other people can see your published content.
  • Subsidiaries and Affiliates; Service Providers. We may from time to time use the services of affiliates, subsidiaries and unrelated service providers in the operation of the Site, and may disclose personal information to them in the course of our use of their services. For example, we may use the services of third-party hosting companies to host the operation of the Site. This may involve the hosting of data, including personal information, on servers operated by those hosting
  • Legal Requests; Emergencies; Jurisdictions. We cooperate with law enforcement inquiries and demands for information that are made under force of law. We are also cognizant of the need to address emergencies. Therefore, we may disclose your personal information (a) to any governmental authority as part of an investigation to determine our compliance with any applicable law, rule, or regulation (including privacy laws, rules, and regulations), (b) in response to a court order, subpoena, discovery request, or other lawful judicial or administrative proceeding, (c) as otherwise required under any

applicable law, rule, or regulation, and (d) in good faith, to protect or defend our rights or property or those of other users. Finally, please note that in some cases, personal information that we collect may be stored or processed outside of The United States of America. In such cases, we continue to protect the information with appropriate safeguards, but it may be subject to the legal jurisdiction of those countries and governmental authorities in those countries.

  • We may also disclose personal information to the acquirer or its agents in the course of the sale of our business. If we do this, the disclosure will be subject to confidentiality arrangements customary in such

Legal basis for processing Personal Information (EEA visitors only)

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal 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 also have a legal obligation to collect personal information from you.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

Use of Navigational Information

We use Navigational Information to operate and improve the Websites and Services. We may also use Navigational Information alone or in combination with Personal Information to provide you with personalized information about The Dawson Academy.

Use of Credit Card Information

If you give us credit card information, we use it solely to collect payment from you. We use a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use information you provide except for the sole purpose of credit card processing on our behalf.

Security of your Personal Information

We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All Personal Information is protected using appropriate physical, technical and organizational measures.

Social Media Features

Our Websites include Social Media Features, such as the Facebook Like button and Widgets, such as the Share This button or interactive mini-programs that run on our sites. These features may collect your IP address, which page you are visiting on our sites, and may set a cookie to enable the feature to function properly.

Social Media Features and Widgets are either hosted by a third party or hosted directly on our Websites. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.

External Websites

Our Websites provide links to other websites. We do not control, and are not responsible for, the content or practices of these other websites. Our provision of such links does not constitute our endorsement of these other websites, their content, their owners, or their practices. This Privacy Policy does not apply to these other websites, which are subject to any privacy and other policies they may have.

Public Forums

We offer publicly accessible message boards, blogs, and community forums. Please keep in mind that if you directly disclose any information through our public message boards, blogs, or forums, this information may be collected and used by others. We will correct or delete any information you have posted on the Websites if you so request.

Cookies

A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the site again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information.

Cookies provide a convenience feature to save you time, or tell the Web server that you have returned to a specific page. For example, if you personalize pages on our Websites, or register for Services, a cookie helps us to recall your specific information on subsequent visits. When you return to the same Website, the information you previously provided can be retrieved, so you can easily use the customized features.

Cookies set by the website owner (in this case, The Dawson Academy) are called “first party cookies”. Cookies set by parties other than the website owner are called “third party cookies”. Third party cookies enable third party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics). The parties that set these third-party cookies can recognize your computer both when it visits the website in question and when it visits certain other websites.

Why do we use cookies?

We use first party and third party cookies for several reasons. Some cookies are required for technical reasons in order for our Websites to operate, and we refer to these as “essential” or “strictly necessary” cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our Websites and Services. For example, The Dawson Academy keeps track of the Websites and pages you visit within The Dawson Academy site, in order to determine what portion of the Website is the most popular or most used. This data is used to deliver customized content and promotions within the Website and to customers whose behavior indicates that they are interested in a particular subject area. Third parties serve cookies through our Websites for advertising, analytics and other purposes. This is described in more detail below.

What types of cookies do we use and how do we use them?

These are the specific types of first and third party cookies served through our Websites and the purposes they perform. These cookies include:

Essential website cookies: These cookies are strictly necessary to provide you with services available through our Websites and Services and to use some of its features, such as access to secure areas.

Performance and functionality cookies: These cookies are used to enhance the performance and functionality of our Websites and Services but are non-essential to their use. However, without these cookies, certain functionality may become unavailable.

Analytics and customization cookies: These cookies collect information that is used either in aggregate form to help us understand how our Websites and Services are being used or how effective our marketing campaigns are, or to help us customize our Websites for you.

Social networking cookies: These cookies are used to enable you to share pages and content that you find interesting on our Websites and Services through third party social networking and other websites. These cookies may also be used for advertising purposes too.

How can I control cookies?

You have the right to decide whether to accept or reject cookies. You can exercise your cookie preferences by clicking on the appropriate opt-out link in the cookie notification pop-up on the website.

You can set or amend your web browser controls to accept or refuse cookies. If you choose to reject cookies, you may still use our website though your access to some functionality and areas of our website may be restricted. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser’s help menu for more information.

Essential website cookies: Because these cookies are strictly necessary to deliver the Websites to you, you cannot refuse them. You can block or delete them by changing your browser settings however, as described above.

Third-party cookies

We may use third-party advertising companies, such as AdRoll to serve advertisements on our behalf. These companies may use cookies or other technologies (such as a 1×1 pixel .gif file, also known as a web beacon), to tailor advertisements you see on the Website and third party websites, to track your response to advertisements, report on visitor interaction and to measure the effectiveness of advertisements. To opt out of these communications, please visit app.adroll.com/optout/.

Our Retention of Your Information

We retain personal information for only as long as required to fulfill the identified purposes for which it was collected or as required by law. When you register on the Site, archived personal information that you have provided will not ordinarily be erased unless and until your entire account on the Site is deleted, and even then we may retain some or all of your personal information on back-up files; provided, however, we assume no obligation or guarantee to archive any information and do not warrant that any archived information will later be made available to you.

If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us or ceased using your Website account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

International Transfer of Information

International Transfers within The Dawson Academy’s Entities

To facilitate our global operations, we may transfer information to our affiliated entities and allow access to that information from countries in which The Dawson Academy’s affiliated entities have operations for the purposes described in this policy.

This Privacy Policy shall apply even if we transfer Personal Information to other countries. We have taken appropriate safeguards to ensure that your Personal Information is subject to an adequate level of data protection. When we share information about you within and among The Dawson Academy’s affiliated entities, we make use of standard contractual data protection clauses, which have been approved by the European Commission, and we rely on the EU-U.S.

Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework to safeguard the transfer of information we collect from the European Economic Area and Switzerland. Please see our Privacy Shield Notice below for more information.

Privacy Shield Notice

The Dawson Academy participates in the EU-U.S. Privacy Shield Framework and the Swiss–U.S. Privacy Shield Framework. The following affiliated entities adhere to the Privacy Shield principles: The Dawson Academy UK, The Dawson Academy Poland, and The Dawson Academy Spain. In compliance with the Privacy Shield framework, The Dawson Academy is committed to subjecting all Personal Information received from European Union (EU) member countries and Switzerland, to an adequate level of data protection and all of the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov.

The Dawson Academy is responsible for the processing of personal data it receives under the Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. The Dawson Academy complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, The Dawson Academy is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, The Dawson Academy may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

You may direct any inquiries or complaints related to our Privacy Shield compliance to info@thedawsonacademy.com.

How to Access & Control Your Personal Data

Reviewing, Correcting and Removing Your Personal Information You have the following data protection rights:

You can request access, correction, updates or deletion of your personal information.

You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.

If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

You have the right to complain to a data protection authority about our collection and use of your personal information. To exercise any of these rights, please contact us at info@thedawsonacademy.com or by mail to The Dawson Academy, 100 Second Avenue South

Suite 303S, St. Petersburg, FL 33701, Attention: Marketing. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.

To Unsubscribe From Our Communications

You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our e-mails, updating your communication preferences, or by sending us email at info@thedawsonacademy.com or postal mail to The Dawson Academy, 100 Second Avenue South

Suite 303S, St. Petersburg, FL 33701, Attention: Marketing. Customers cannot opt out of receiving transactional emails related to their account with us or services purchased.

Security

TDA strives to protect your personal information and other information you provide to us, such as

login passwords for third party websites. We make commercially reasonable efforts to ensure the security of your personal information on our system and the security of other information you provide to us.

Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information and other information, we cannot warrant the security of any information you transmit to us.

Other Information Collectors

Except as otherwise expressly included in this Privacy Policy, this document only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties through the Site, different rules may apply to their use, collection and disclosure of the personal information you disclose to them. Since we do not control the information use, collection or disclosure policies of third parties, you are subject to their privacy policies. We encourage you to ask questions before you disclose your personal information to others.

Questions?

It is our goal to make our privacy practices easy to understand. If you have questions or concerns, please contact us at, info@thedawsonacademy.com or,

ATTN: Privacy Officer

The Dawson Academy

390 4th Street North, Suite 200

St. Petersburg, FL 33701

Last updated on August 14, 2018

Version 2.1