PRIVACY POLICY

OUR POLICY

Welcome to the website (the “Site”) of Sunday Digital Publishing Ltd (“Company,” “we,” “us,” “our”). This Site is operated by SUNDAY and has been created to provide information about SUNDAY and our online video education services, mobile applications and related services (together with the Site, the “Services”) to our Service visitors (“you”, “your”). This Privacy Policy sets forth SUNDAY’s policy with respect to information including personally identifiable data (“Personal Data”) and other information that is collected from visitors to the Site and Services.

INFORMATION WE COLLECT

When you interact with us through the Services, we may collect Personal Data and other information from you, as further described below.

Personal Data That You Provide Through the Services: We collect Personal Data from you when you voluntarily provide such information, such as when you contact us with inquiries, respond to one of our surveys, register for access to the Services, or use certain Services. Wherever SUNDAY collects Personal Data we make an effort to provide a link to this Privacy Policy.

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to the Services, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of SUNDAY and the authorized third parties referred to herein located in the United States.

OTHER INFORMATION

Non-Identifiable Data: When you interact with SUNDAY through the Services, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. SUNDAY may store such information itself or such information may be included in databases owned and maintained by SUNDAY affiliates, agents or service providers. The Services may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, and the domain names of our visitors’ Internet service providers. It is important to note that no Personal Data is available or used in this process.

In operating the Services, we may use a technology called “cookies.” A cookie is a piece of information that the computer that hosts our Services gives to your browser when you access the Services. Our cookies help provide additional functionality to the Services and help us analyze Services usage more accurately. For instance, our Site may set a cookie on your browser that allows you to access the Services without needing to remember and then enter a password more than once during a visit to the Site. In all cases in which we use cookies, we will not collect Personal Data except with your permission. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Service features.

Aggregated Personal Data: In an ongoing effort to better understand and serve the users of the Services, SUNDAY often conducts research on its customer demographics, interests and behavior based on the Personal Data, and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and SUNDAY may share this aggregate data with its affiliates, agents, and business partners. This aggregate information does not identify you personally. SUNDAY may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

Location Information: Our Service may collect and use your location information (for example, by using the GPS on your mobile device) to provide certain functionality of our Service. If you choose to enable our location features, your location information may be publicly displayed within the Service. Please keep in mind that other users can see this information about you, and they may use it or disclose it to other individuals or entities outside of our control and without your knowledge. Your location information may be subject to abuse, misuse, and monitoring by others, so please be careful if you choose to enable location functionality. We may also use your location information in an aggregate way, as described above in the “Aggregated Personal Data” section.

OUR USE OF YOUR PERSONAL DATA AND OTHER INFORMATION

SUNDAY uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Data you provide to answer your question or resolve your problem. Also, if you provide Personal Data in order to obtain access to the Services, we will use your Personal Data to provide you with access to such services and to monitor your use of such services. SUNDAY and its subsidiaries and affiliates (the “Related Companies”) may also use your Personal Data and other personally non-identifiable information collected through the Services to help us improve the content and functionality of the Services, to better understand our users, and to improve the Services. SUNDAY and its affiliates may use this information to contact you in the future to tell you about services we believe will be of interest to you. If we do so, each marketing communication we send you will contain instructions permitting you to “opt-out” of receiving future marketing communications. In addition, if at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below.

Third-Party Advertising Partners: We use third-party service providers to serve advertisements (banners or links) on our behalf across the Internet. These advertising service providers may collect non-identifiable information about your visits to our website, and your interactions with our products and services. Such non-identifiable information does not include your name, address, email addresses, or other personal information. The information is collected through the use of cookies and pixel tags (also known as action tags), which is the industry-standard technology used by most major websites. In addition to the information about your visits to our website, our service providers may also use the information about your visits to other websites to target advertisements for classes available from SUNDAY.

If SUNDAY intends on using any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected.

OUR DISCLOSURE OF YOUR PERSONAL DATA AND OTHER INFORMATION

SUNDAY is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:

Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.

Related Companies: We may also share your Personal Data with our Related Companies for purposes consistent with this Privacy Policy.

Agents, Consultants and Related Third Parties: SUNDAY, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases, and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.

Legal Requirements: SUNDAY may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of SUNDAY, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.

EXCLUSIONS

This Privacy Policy does not apply to any Personal Data collected by SUNDAY other than Personal Data collected through the Services. This Privacy Policy shall not apply to any unsolicited information you provide to SUNDAY through the Services or through any other means. This includes, but is not limited to, information posted to any public areas of the Services, such as forums, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and SUNDAY shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.