The Information We Collect
How We Use Your Information
Legal Bases for Use of Your Information
Cookies and Similar Technologies
Online Analytics and Advertising
How We Share and Disclose Your Information
Retention of Your Information
Data Subject Rights and Your Choices
Third-Party Links and Features
How We Protect Your Information
California Privacy Rights
ICH Contact Information
Information We Collect
We obtain information about you through the means discussed below when we provide the Services. Please note that we need certain types of information so that we can provide the Services to you. If you do not provide us with such information, or ask us to delete it, you may no longer be able to access or use our Services.
Information You Provide to Us
We collect a variety of information that you provide directly to us. For example, we collect information from you through:
The Services you use or processing your orders
Requests or questions you submit to us via online forms, email, or otherwise
Your participation in sweepstakes, contests, or surveys
Any reviews that you submit about the Services
Account registration and administration of your account
Uploads or posts to the Services
Requests for customer support and technical assistance
Information about you. While parts of the Services may not require you to provide any information that can directly identify you by name (such as if you choose to browse the website without logging in), the specific types of information we collect will depend upon the Services you use, how you use them, and the information you choose to provide. The types of data we collect directly from you include:
Name, if you choose to provide it
Log-in credentials, if you create an ICH account
Billing information, such as shipping address of a gift card recipient, credit or debit card number, verification number, and expiration date
Information about purchases or other transactions with us
Information about your customer service interactions with us
Demographic information such as your gender or other information you choose to provide as part of your ICH profile
User-generated content you post in public forums such as when you comment on or review a class
Any other information you choose to directly provide to us in connection with your use of the Services
Information about others. If you request that your purchase be provided to someone other than yourself (such as a gift recipient), we use the information you provide about the other person to fulfill the shipment.
Information We Collect Through Automated Means
When you use our Services, we collect certain information as described in this Section. As discussed further below, we and our service providers (which are third-party companies that work on our behalf) may use a variety of technologies, including cookies and similar tools, to assist in collecting this information.
Websites. When you use our website, we collect and analyze information such as your IP address, browser types, browser language, operating system, software and hardware attributes (including device IDs) referring and exit pages and URLs, the number of clicks, pages viewed, and the order of those pages, the date and time you used the Services, error logs, and other similar information.
Mobile Applications and Software. When you use an ICH mobile application or software, we automatically receive certain information about the mobile phone, tablet, or computer used to access the application or software, including device identifiers, IP address, operating system, version, Internet service provider, browser type, domain name, and other similar information, whether and when you update the app, date and time of use, and how you use the app.
Location Information. When you use the Services, we and our service providers may automatically collect general location information (e.g., IP address, city/state, and or postal code associated with an IP address) from your computer or mobile device.
Information We Collect From Social Media and Other Content Platforms
Information We Collect from Others
We may receive additional information such as demographic and statistical information from third parties, such as business partners, marketers, researchers, analysts, and other parties that we may attribute to you based on your assignment to certain statistical groups. We use this information to supplement the information that we collect directly from you in order to derive your possible interests and to provide more relevant experiences for you and improve our products, analytics, and advertising.
HOW WE USE YOUR INFORMATION
We, or our service providers, use your information for various purposes depending on the types of information we have collected from and about you, in order to:
Complete a purchase or provide the Services you have requested, including invoicing and accounting
Respond to your request for information and provide you with more effective and efficient customer service
Provide you with updates and information about classes in which you have enrolled
Contact you by email, postal mail, or phone regarding ICH and third-party products, services, surveys, research studies, promotions, special events and other subjects that we think may be of interest to you
Customize the advertising and content you see on the Services
Help us better understand your interests and needs, and improve the Services, including through research and reports, and test and create new products, features, and services
Secure our websites and applications, and resolve app crashes and other issues being reported
Comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others
Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others
Aggregate/Anonymous Data. We may aggregate and/or anonymize any information collected through the Services so that such information can no longer be linked to you or your device. We may use such information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors.
LEGAL BASES FOR USE OF YOUR INFORMATION
Where use of your information is necessary to perform our obligations under a contract with you (for example, to comply with: the terms of service of our websites which you accept by browsing the websites/registering; and/or our contract to provide our Services to you);
Where use of your information is necessary for our legitimate interests or the legitimate interests of others (for example, to provide security for our website and applications; operate our business and our Services; make and receive payments; comply with legal requirements and defend our legal rights; prevent fraud and to know the customer to whom we are providing Services);
Where we are required to process information in accordance with an EU Member State legal obligation; or
Where we have your consent, in accordance with applicable law.
COOKIES AND SIMILAR TECHNOLOGIES
To collect the information in the “Information We Collect Through Automated Means” section above, we and our service providers use Internet server logs, cookies, tracking pixels, and other similar tracking technologies. We use these technologies in order to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences. Cookies are small text files that are placed on your computer or mobile device when you visit a site that enable us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Services you have visited; (iv) enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions. Some cookies are placed in your browser cache while those associated with Flash technologies are stored with your Adobe Flash Player files.
As we adopt additional technologies, we may also gather information through other methods. Please note that you can change your settings to notify you when a cookie is being set or updated or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). You can also manage the use of Flash technologies, including flash cookies and local storage objects, with the Flash management tools available at Adobe’s website. Please note that by blocking, disabling, or managing any or all cookies, you may not have access to certain features or offerings of the Services.
Types of Information Collected and Reasons for Collection
Cookies help us to better understand your expectations of our Site and, as a result, allow us, among other strategies, to offer our visitors a pleasant and sustainable experience. Here are examples of the types of information that we collect through Cookies:
The number of users visiting the ICH Site, the frequency with which the Site was viewed, the pages viewed, the clicks made on the Site and the total duration of navigation on the Site;
The name of the website visited prior to the ICH Site;
Whether you are visiting our Site for the first time or not;
Your viewing preferences (e.g. layout, sizing preferences, language, etc.);
Your purchases and your orders; and
Your user name, your password, the type of browser used, and your IP address, so that we can identify you during your next visits.
In addition, Cookies allow us to do the following:
Customize your visit: We may use information collected during your visit to facilitate your next visit to our Site;
Customize the advertising and marketing messages that appear on the Site, whether ours or those of third parties; and
Analyze customer trends: We compile information on individual Site visits and analyze them as a whole in aggregated form.
Type of Cookies We Use
We use first-party and third-party cookies for several reasons. Some cookies are required for technical reasons in order for our Site to operate, and we refer to these as “essential” or “strictly necessary” Cookies. Other Cookies enable us to track and target the interests of our users and to enhance the experience on our Site. Third parties also serve Cookies through our Site for advertising, analytics, and other purposes. The specific types of first and third-party cookies served through our Site and the purposes they perform are described in more detail below.
These cookies are created by ICH. They are, for the most part, used to allow you to browse our Site and use its features. First-party cookies include:
Essential Website Cookies: These cookies are strictly necessary to provide you with services available through our Site and to use some of its features, such as access to secure areas.
Functional Cookies: These cookies allow you to browse our Site or benefit from some of its features, such as memorizing language preferences or placing orders online.
Analytics Cookies: These cookies allow us to collect statistics (aggregated and anonymous) on the usage of the Site by you and other visitors. This information helps us improve the features offered on its Site.
In addition to our proprietary Cookies, some third-party and affiliated companies may place Cookies on your computer, access them and associate web beacons with them. These cookies enable third party features or functionalities to be provided on or through the Site. The parties that set these third-party cookies can recognize your device both when it visits our Site and also when it visits certain other websites. Third-party cookies include:
Functional Cookies: These Cookies are defined by third parties who support our Site and they allow you to use useful services and features, such as instant messaging support.
Online Behavioural Advertising Cookies: These Cookies are defined by our advertising partners and collect data about your browsing habits, as well as your preferences for products and services. This information allows ICH and the ad networks that we work with to display relevant ads on the most relevant pages of partner sites and the ICH Site. For example, third parties or affiliates may manage ICH advertising programs on a non-ICH site.
Duration of Storage of Cookies on Your Device
The duration of storage of Cookies on your device may vary, depending on the category to which they belong: temporary or permanent.
We use temporary cookies on all of our secure pages to assign and register a session ID. This identifier is also used for internal reporting purposes. It does not allow us to identify you personally by name and this type of cookie does not leave any information recoverable on your hard drive. Most of our proprietary Cookies fall into this category and expire when you close your Internet browser.
Our first-party Cookies and third-party Cookies are permanent Cookies. They allow us to understand visitors’ browsing behavior over a longer period of time or to provide you with additional features related to your Site customization requests and the content that you have saved or stored. They can stay on your computer for 24 hours, a week or several years, depending on their function. This means that these cookies survive after your browser is closed and can be used by our Site to recognize your computer when you re-open your browser later.
We only place cookies on your device after you give us permission. If you do not want to receive some of the categories of Cookies used on our Site, you can use the means described below to disable them. Note, however, that we will still need to set a cookie on your device to remember your preferences when you visit our Site again from a single browser.
At the moment, it is technically impossible for you to synchronize your settings between your browsers and your devices (your computer or your smartphone). You must set them on each browser/device that you currently use and each time you use a new browser or device.
You can decide whether to accept or reject Cookies. You can exercise your cookie preferences by managing Cookies from your web browser. As the means by which to activate or deactivate cookies varies from one web browser to another, you should visit your web browser’s help menu for more information on Cookie preferences. You can also configure your browser at any time to be notified of the receipt of a cookie so that you can decide whether you want to accept it or not. Cookies do not under any circumstances read the data from your hard drive and you can delete them from your computer at any time. You can also manage the use of Flash technologies, including flash cookies and local storage objects with the Flash management tools available at Adobe’s website.
If you choose to deactivate all cookies, you may continue to use certain parts of our Site. However, some useful features may not work anymore.
Please note that if you have disabled one or more cookies, we may continue to use the information that was collected by such Cookies before they were deactivated. However, we will cease to collect any information via the opted-out Cookie once a Cookie has been deactivated.
Changes to the Cookies Notice
ONLINE ANALYTICS AND ADVERTISING
We may use third-party web analytics services (such as those of Google Analytics) on our Services to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention, and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on.
If you receive an email from us, we may use certain analytics tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.
The Services may integrate third-party advertising technologies that allow for the delivery of relevant content and advertising on the Services, as well as on other websites you visit and other applications you use. The ads may be based on various factors such as the content of the page you are visiting, the information you enter such as your age and gender, your searches, demographic data, user-generated content, and other information we collect from you. These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored to your interests.
Third parties may also place cookies or other tracking technologies on your computer, mobile phone, or other devices to collect information about you as discussed above. These third parties (e.g., ad networks and ad servers such as Google Analytics, DoubleClick, and others) may also serve tailored ads to you as you use the Internet and Internet-connected applications, and access their own cookies or other tracking technologies on your computer, mobile phone, or other devices you use to access the Services to assist in this activity.
Please note that if you exercise the choices above, you will still see advertising when you use the Services, but it will not be tailored to you based on your online behavior over time.
Notice Concerning Do Not Track
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our website for third-party purposes, and that is why we provide the variety of opt-out mechanisms listed above. However, we do not currently recognize or respond to browser-initiated DNT signals.
HOW WE SHARE AND DISCLOSE YOUR INFORMATION
ICH will share your information in the following ways:
Affiliates and Subsidiaries. We may share information we collect within the Yanka Industries family of companies to deliver products and services to you, ensure a consistent level of service, and enhance our products, services, and your customer experience.
Service Providers. We provide access to or share your information with select third parties who perform services on our behalf. They have access to perform these services but are prohibited from using your information for other purposes. They provide a variety of services to us, including billing, sales, marketing, product content and features, advertising, analytics, research, customer service, data storage, security, fraud prevention, payment processing, and legal services.
Business Transfers. As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions (including in contemplation of such transactions), user information may be among the transferred assets. If a portion or all of our assets are sold or transferred to a third party, customer information (including your email address) would likely be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable laws, we will comply with such restrictions.
Public Forums. Certain features of our Services make it possible for you to share comments publicly with other users. Any information that you submit through such features is not confidential, and we may use it for any purpose (including in testimonials or other marketing materials). Any information you post openly in these ways will be available to the public at large and potentially accessible through third-party search engines. Accordingly, please take care when using these features.
Aggregate/Anonymous Information. From time to time, we may share Aggregate/Anonymous Information about the use of the Services, such as by publishing a report on usage trends. The sharing of such data is unrestricted.
RETENTION OF YOUR INFORMATION
We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.
DATA SUBJECT RIGHTS AND YOUR CHOICES
You have certain rights with respect to your information as further described in this section.
Your Legal Rights
If you would like further information in relation to your legal rights under applicable law or would like to exercise any of them, please contact us using the information in the “Contact Information” section below at any time. Your local laws (e.g., in the EU) may permit you to request that we:
provide access to and/or a copy of certain information we hold about you
prevent the processing of your information for direct marketing purposes (including any direct marketing processing based on profiling)
update information that is out of date or incorrect
delete certain information which we are holding about you
restrict the way that we process and disclose certain of your information
transfer your information to a third party provider of services
revoke your consent for the processing of your information
We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with the information necessary to confirm your identity before responding to your request.
Marketing Communications and Sharing
THIRD-PARTY LINKS AND FEATURES
The Services are intended for general audiences and not for children under the age of 13. If we become aware that we have inadvertently collected “personal information” (as defined by the United States Children’s Online Privacy Protection Act) from children under the age of 13 without valid parental consent, we will take reasonable steps to delete it as soon as possible. We do not knowingly process data of EU residents under the age of 16 without parental consent. If we become aware that we have collected data from an EU resident under the age of 16 without parental consent, we will take reasonable steps to delete it as soon as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws.
The information discussed in this Policy is processed in the United States by ICH, whose principal office in the United States is located at 660 4th Street #443, San Francisco, CA 94107.
If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. As described above, we also may subcontract the processing of your data to, or otherwise share your data with, other members within the ICH group of companies, service providers, and business partners in countries other than your country of residence, including the United States, in accordance with applicable law. Such third parties may be engaged in, among other things, the provision of Services to you, the processing of transactions, and/or the provision of support services. By providing us with your information, you acknowledge any such transfer, storage, or use. ICH will take reasonable and appropriate steps necessary to ensure that any third party who is acting as a “data processor” under EU and Swiss terminology is processing the personal data we entrust to them in a manner that is consistent with the EU-US and Swiss-US Privacy Shield Principles. ICH is potentially liable in cases of onward transfer to third parties of data of EU and Swiss individuals received pursuant to the EU-US and Swiss-US Privacy Shield, respectively.
If applicable, you may make a complaint to the data protection supervisory authority in the country where you reside. Alternatively, you may seek a remedy through local courts if you believe your rights have been breached.
HOW WE PROTECT YOUR INFORMATION
ICH takes technical and organizational security measures to protect the information provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error-free. Please keep this in mind when disclosing any information to ICH via the Internet.
CALIFORNIA PRIVACY RIGHTS
California law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of “personal information” (as defined by applicable California law) with third parties for their direct marketing purposes. ICH does not share your personal information with third parties for their own direct marketing purposes.