Studio Privacy Policy

Effective Date: March 19, 2021

Who We Are and What This Policy Covers

At Openmind Learning, Inc. ("Studio", "we", "us"), we recognize that privacy is very important and value your privacy. In this Privacy Policy ("Policy"), we describe how we collect, use, and disclose personal information that we obtain about our customers and users of our website (including studio.com)("Sites"), our mobile application (the "App") and the services available through our Site (collectively, the Site, the App, and the services available therein are the "Services"). Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.

Applicable Terms

Your use of our Services, and any dispute over privacy, is subject to this Policy, the respective terms of use (the "Terms"), between you and Studio, such as our Terms of Service and any other relevant agreements. The applicable Terms are incorporated by reference into this Policy, including their applicable limitations on liability and the resolution of disputes. By disclosing your personal information to us or using our Services, you understand and agree that Studio may collect, use, and disclose your personal information in accordance with this Policy and the applicable Terms.

Information We Collect

We generally collect information in the following ways: if and when you provide information directly to us, automatically through our Services, and from third-party sources. Let's go over the information that we collect below.

Information You Provide to Us

It's probably no surprise that we collect information that you provide to us. The amount and type of information depends on how you interact with our Services. Here are some examples:

• Basic Account Information: While you can browse parts of our website without registering, we ask you to sign up for a studio.com account to access certain parts of the Services (e.g., to participate in one of our classes). When you sign up for a studio.com account, we may ask you for basic personal information such as your email address, first name, and last name. We may also allow you to submit additional voluntary account information, such as a profile picture, your bio, or country/city you're located in. You can also sign up to receive email newsletters and promotional offers from us or to join a waitlist for a class by submitting your email address.
• Public Profile Information: If you have an account with us and enroll in a Studio class, certain of your profile information will be used for your public profile. For example, your username, profile picture, and self-reported location of residence are part of that public profile, along with any other information you choose to put into your public profile, such as your bio. Your full public profile is visible to other registered Studio users, while your username and profile picture are visible to any of our website visitors, so please keep that in mind when deciding what information you would like to include.
• User Content: The content that you create and submit (e.g., images, videos, recordings, or other classwork) through the Services will be visible to registered users, such as your tutors and other students. We maintain a copy of such content and may append other information to it, such as comments and ratings from your instructors or peers. If you choose to engage in student discussion boards, blogs, or similar features and submit comments, ratings, or other content, we maintain a copy of this content. Your completed project submissions are made visible to all website visitors in our student galleries. You may remove your content from the galleries directly within your account settings or by contacting us at privacy@studio.com. We may also collect certain information metadata associated with your content. Certain public user content may also be viewable by other website visitors and registered users of the Services.
• Communications with Us: You may also provide us information when you respond to surveys, communicate with us by email, mail, chat, phone, or otherwise regarding the Services or a support question. We collect and maintain a record of your contact details, communications and our responses.
• Other Information We Collect Regarding Your Usage of Our Services: We may also collect information about your use of our Services, such as your order and subscription history and purchases. We may also collect certain personal information about you from third parties, such as ratings, comments or grades provided by your instructor.
• Instructor Accounts: If you are a class instructor and use the Studio App, we collect personal information from you through the Studio App, including your name, profile picture, and bio, as well as content you provide through the app, such as comments and ratings of student work or other content that you submit through the App.

Information We Collect Automatically

We may also collect personal information about how you use the Services (e.g., using cookies and pixel tags), such as IP address, advertising ID, location information, browser type, device type, domain name, the website that led you to our Services, the website to which you go after leaving our Services, the dates and times you access our Services, and the links you click and your other activities within the Services. We may also use pixels in HTML emails to understand if individuals read the emails we send to them ("Usage Data"). We may combine this information with other information that we have collected about you, including, where applicable, your name and other personal information. (For more information, see the Cookies and Tracking Information section below.)

How and Why We Use Information

Purposes for Using Information

We use information about you as mentioned above and for the purposes listed below:

• To provide and maintain our Services—for example, to set up and maintain your account; to host your profile; to fulfil your purchases; to authenticate users; to perform technical operations, such as updating software; and for other customer service and support related purposes
• To provide you with the information or services that you have requested; to communicate with you about your use of our Services, to respond to your inquiries, and for other customer service purposes
• To further develop and improve our Services—for example, by adding new features that we think our users will enjoy or will help them to create and manage their profiles more efficiently
• To communicate with you, for example through an email, about newsletters, offers and promotions offered by Studio and others we think will be of interest to you, solicit your feedback, or keep you up to date on Studio and our products
• To monitor and analyze trends and better understand how users interact with our Services, which helps us improve our Services and make them easier to use
• To monitor and prevent any problems with our Services, protect the security of our Services, detect and prevent fraudulent transactions and other illegal activities, fight spam, and protect the rights and property of Studio and others
• To personalize your experience using our Services, provide content recommendations, and target our marketing messages to groups of our users
• To conduct audits and assessments of our business operations, security controls, financial controls, records and information management program, and otherwise relating to the administration of our general business, accounting, record keeping and legal functions. These purposes are based on our legitimate interest in operating our business and maintaining adequate internal records and safeguards.
• To protect our business operations and secure our network and information technology assets and services; to prevent and detect fraud, unauthorized activities, access and other misconduct; where we believe necessary to investigate, prevent or take action regarding suspected violations of our Terms and other agreements, as well as fraud, illegal activities and other situations involving potential threats to the rights or safety of any person or third party; and as necessary to defend Studio's legal interests and rights.
• To comply with the law or legal proceedings, including responding to subpoenas, court orders, and other lawful requests by regulators and law enforcement, or to national security or law enforcement disclosure requirements.
• We may also use your personal information for other purposes, where you have consented.
• We may also use aggregate and deidentified information for various research, development, product improvement, analytics and other purposes.

How We Disclose Information

We may disclose information about you as spelled out below:

• Subsidiaries and Affiliates: With our affiliated companies whose use and disclosure of such personal information is subject to this Policy.
• Service Providers: We may share information about you with our third-party service providers who need to know information about you in order to provide their services on our behalf, or to provide their services to you or your site. This group includes, for example, vendors that help us provide our Services to you (like auditors, advisors, consultants, customer service and/or support providers, payment providers that process your credit and debit card information, fraud prevention services that allow us to analyze fraudulent payment transactions, postal and email delivery services that help us stay in touch with you, customer chat and email support services that help us communicate with you, our hosting providers, and those that assist us with our marketing efforts (e.g. by providing tools for identifying a specific marketing target group or improving our marketing campaigns), those that help us understand and enhance our Services (like analytics providers), and companies that make products available on our websites, who may need information about you in order to, for example, provide technical or other support services to you.
• Third Parties: With third parties that provide advertising, campaign measurement, online and/or mobile analytics and related services. These third parties may receive or access browsing history and/or other data about your use of the Sites, in order to help us better reach individuals with relevant ads, measure our ad campaigns and/or to better understand how individuals interact with our Sites over time and across devices.
• Legal Requests: We may disclose information to comply with the law or legal proceedings, for example, in response to a subpoena, court order, or other governmental request.
• To Protect Rights, Property, and Others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Studio, third parties, and/or others, and/or as evidence in litigation in which we are involved
• Business Transfers: In connection with any actual or contemplated merger, sale of company assets, or acquisition of all or a portion of our business by another company, or in the unlikely event that Studio goes out of business or enters bankruptcy, user information would likely be one of the assets that is transferred or acquired by a third party.
• Aggregated and De-identified Data: We may share aggregate or de-identified information with third parties for research, marketing, advertising, analytics and/or other purposes.

Cookies and Tracking Information

We and our third-party providers use cookies, clear GIFs/pixel tags, JavaScript, local storage, log files, and other mechanisms to automatically collect and record information about your browsing activities and use of the Sites and other Services. We may combine this "usage data" with other personal information we collect about you. We use this usage data to understand how our Services are used, track bugs and errors, provide and improve our Services, verify account credentials, allow logins, track sessions, prevent fraud, and protect our Services, as well as for targeted marketing and advertising, to personalize content and for analytics purposes.

Cookies

Cookies are alphanumeric identifiers that we transfer to your computer's hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site, while others are used to enable a faster log-in process or to allow us to track your activities while using our Site. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Some of the Services may not work properly if you disable cookies.

Pixel Tags

Pixel tags are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer's hard drive, clear GIFs are embedded invisibly on web pages. We may use pixel tags (also referred to as web beacons, web bugs or clear GIFs), in connection with our Services to, among other things, help us manage ads and content, and compile statistics about usage of our Services. We may also use pixel tags in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

You can block or disable cookies for the device and browser you are using, through your browser settings; however, certain features on our Sites may not be available or function properly if you block or disable cookies. Our Sites currently do not respond to "do not track" signals.

Interest Based Advertising

We may work with third-party ad networks, channel partners, measurement services, and others ("third-party ad companies") to display advertising on our Services and to manage our advertising on third-party sites and online services. We and these third-party ad companies may use cookies, pixels tags, and other tools to collect activity information on our Services (as well as on third-party sites and services), as well as IP address, device ID, cookie and advertising IDs, other identifiers, and general location information; we and these third-party ad companies use this information to provide you more relevant ads and content and to improve and evaluate such ads and content. **

Ad Choices

You can learn more about the information collection practices and "opt-out" procedures of many third-party ad companies by visiting networkadvertising.org/optout_nonppii.asp. Opting out of participating ad networks does not opt you out of being served advertising. You may continue to receive generic or "contextual" ads on our Services. You may also continue to receive targeted ads on other websites from companies that do not participate in the above programs.

Third-Party Sites and Services

Our Services may link to other websites or online services (including those operated by our parent, affiliates, or others) that are not covered by this Policy. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.

In this section we describe the choices you have regarding our collection, use and handling of your personal information.

Your Rights

• Access and Update Information: You may access, update, and delete certain of your personal information by accessing and adjusting your account settings or closing your account. You may also contact us using the information in the How to Reach Us section below to make an access, correction or other privacy request. Please note that we may maintain copies of information that you have updated, modified or deleted, in our business records and in the normal course of our business operations, as permitted or required by applicable law. Further, we may take reasonable steps to verify your identity before granting such access or making corrections.
• Marketing Communications: You may opt out of receiving email marketing communications from us by using the unsubscribe link in any such email we send to you. Please note that we may still send you transactional emails, such as emails related to your account or subscriptions.

Children

Our Services are not targeted and directed at children under thirteen years of age (13) and we do not knowingly collect any personal information from a child under 13. If you believe we have inadvertently collected personal information about a child, please contact us and we will take steps to delete this information.

How to Reach Us

If you have a question about this Policy, or you would like to contact us about privacy, please contact us at privacy@studio.com. Studio's (Openmind Learning, Inc.'s) physical address is 1149 N Gower St #239, Los Angeles, CA 90038.

Changes to This Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Services. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Services.