Effective: April 13, 2020
Filmbook provides services, content and functionality (collectively “Services”) through its mobile application (“App”) and through its websites at www.filmbook.com and www.filmbook.com/cosmetology (including all subsidiary web pages (“Site”). The Services consist of instructional videos, text, images and test questions.
Information we collect
When you configure the Filmbook App, we collect information about your preferences for the features of the App, such as the subscription option you have purchased, a username of your choice, the color and style of App features, and the state in which you will take your licensing exam.
When you use the Filmbook App, we collect information about your progress in the classes, such as the answers and scores of your tests and quizzes, your completion of the practices, and your progress in watching the videos. This information is used to save your place in each class, chart your progress, and to allow you to use your account on multiple devices. The foregoing information is necessary to provide the services and failure to provide it will render us unable to provide the Services.
Note that we may aggregate or anonymize personal information we collect so that it is no longer capable of identifying you, in which case that information is no longer considered “personal information” and may be used for any purpose.
Use and sharing of information
We use the information collected in the Filmbook App to personalize and improve your experience and to assist us in handling your support needs, as discussed above in Section 4.
We do not sell your information to outside parties for marketing or advertising. We do share some information with trusted third parties who assist us in operating our software, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. For example, we may share your information with our software developers. In addition, the vendors we use for hosting our database(s) on which your information is stored may have access to your information. We may also release your information when we believe that release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety. We may share information with affiliates, and to any successor entity in the event of a merger, sale of substantially all assets, change of control, or similar transaction.
Accessing and Correcting Your Information
You may send us an email at firstname.lastname@example.org to request access to, update, correct or delete any personal information that you have provided to us. You may also view and update your information in the App by clicking on the menu, then selecting “Settings”.
Do Not Track Disclosure
The Website and App do not monitor for or behave differently if your computer transmits a “do not track” or similar beacon or message.
Technical information; Cookies
All non-personal information collected through the Services—information that is not capable of identifying you—may be used and shared by us without any restriction.
We do not present third-party advertising within the Filmbook app.
Third party links
The Filmbook App may contain links to third-party websites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about third-party sites.
How we protect your information
We maintain appropriate and reasonable administrative, technical and physical measures to safeguard the security of your personal information. However, when you communicate with customer service via email or channels on our App, these communications may not be encrypted. For that reason, we ask that you do not share sensitive information via these communication channels. We are not responsible for illegal actions of third parties (for example, criminal hacking).
If you receive email communications from us and want to opt out of receiving such communications in the future, you can click the “Unsubscribe” link (or similar language) at the bottom of the promotional email.
When you achieve certain milestones in the Filmbook App, such as a perfect score on a test, you may be presented with the option to share this achievement via your social media accounts. You can opt out of sharing this information.
California Online Privacy Protection Act compliance
California Civil Code Section § 1798.83 permits users of our App and Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to email@example.com.
Servers Located in United States
We are an entity located in the United States, and the servers and other technology supporting the operations of the Site and App are located in the United States. If you submit any personal information to the Site and App you understand that you are voluntarily consenting to the transmission of such information to an organization in the United States and your information will be stored and processed in the United States.
GDPR and EEA Residents’ Rights
The General Data Protection Regulation (“GDPR”) is a privacy law that affords certain rights relating to the personal information of individuals in the European Economic Area (“EEA”). Specifically, if you are located in the EEA, you may request that we identify whether we are processing your personal information, our purposes in doing so, how your personal information was obtained (if you did not provide it to us directly), who it may have been shared with, and how long it will be retained. Further, you have the right to request your personal information be corrected if it is inaccurate and, in certain circumstances, may ask that it be erased and withdraw your consent or object to further processing. Finally, subject to certain limitations, and when feasible, you may request a copy of your personal information or that it be transferred to another entity. You will not typically need to pay a fee to exercise any of these rights. But we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Subject to exceptions, if you wish to exercise one of the rights identified above with regarding to personal information subject to this Policy, you may do so by submitting a written request to firstname.lastname@example.org. This is normally free, unless this process is unduly difficult or is clearly unfounded, repetitive, or excessive, in which case we may charge a reasonable fee or decline to respond. Once we have received your request, we will review it and contact you within 30 days of our receipt of your request, but we will notify you of any delay and, in any event, will reply within three (3) months.
Please note that we may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Lastly, if you are located in the EEA and have a concern about our processing of your data, you may have the right to make a complaint to the appropriate data protection authority in the EEA.
Additional Information Regarding Our Processing Under the GDPR
For personal information subject to GDPR, Filmbook acts as a “controller.” Pursuant to the GDPR, Filmbook is required to have a lawful basis for its processing of your personal information. Most of the time, that lawful basis will either be to (1) perform a contractual obligation with you, (2) fulfill legitimate business interests (such as marketing, ensuring the safety, security, and functionality of the Services, and continuing to develop our offerings), (3) comply with a legal obligation, or (4) conduct processing to which you have specifically consented.
For example, we need to process your personal information in order to provide you with the Services. In that circumstance, our lawful basis for the processing your personal information is to perform our contractual obligations to you. Likewise, it may be necessary to our legitimate business interests of growing and continuing our services to use your personal information in order to communicate with you regarding additional services we offer or other information relating to our services that we believe may be of interest.
Please note, as indicated previously, your personal information may be transferred to our servers in the United States. The United States has not received an “adequacy finding” from the European Commission under Article 45 of the GDPR. Filmbook relies on derogations for specific situations as set forth in Article 49 of the GDPR. Filmbook collects and transfers personal information to the U.S. only with your consent, to perform a contract with you, or to fulfill a compelling legitimate interest that does not outweigh your rights or freedoms. We endeavor to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with us and the practices described in this Policy. Filmbook will enter into data processing agreements with its vendors when feasible and appropriate.
Retention of Personal Information
Filmbook is intended for lifetime learning. As a result, we will keep your information (i) until you cancel your subscription and choose to delete the information, (ii) as required by a legal obligation to which we are subject, or (iii) as necessary to comply with legal obligations.
The Application is not directed toward children under the age of thirteen and we do not knowingly collect any personally identifiable information from children under the age of thirteen. If you believe we may have collected personally identifiable information from your child, please contact us at email@example.com and we will promptly delete your child’s information from our records.
Attn: Neal Tillotson
2013 Bainbridge Street, Philadelphia, PA 19146 USA