GALLERR ACADEMY - PRIVACY POLICY

Gallerr Academy understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.

This Policy applies to Our use of any and all data collected by us in relation to your use of Our Site. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Account”	means an account required to access and/or use certain areas and features of Our Site;
“Cookie”	means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 11, below;
“Our Site”	means this website, gallerr.com/academy;
“UK and EU Cookie Law”	means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and
“We/Us/Our”	means Second Front Media Ltd, a limited company registered in England under 9604983, whose registered address is Mercury House, 19-21 Chapel Street, Marlow, SL7 3HN, United Kingdom.

2. Scope – What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. It does not extend to any websites that are linked to from Our Site (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

3. What Data Do We Collect?

Some data will be collected automatically by Our Site, other data will only be collected if you voluntarily submit it, for example, when signing up for an Account. Depending upon your use of Our Site, We may collect some or all of the following data:

• name
• date of birth
• contact information such as email addresses and telephone numbers
• demographic information such as post code, preferences and interests
• financial information such as credit / debit card numbers;
• IP address (automatically collected)
• web browser type and version (automatically collected)
• operating system (automatically collected)
• a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected)

4. How Do We Use Your Data?
   • All personal data is stored securely in accordance with the principles of the Data Protection Act 1998. For more details on security see section 5, below.
   • We use your data to provide the best possible products and services to you. This includes:
     • Providing and managing your access to Our Site
     • Personalising and tailoring your experience on Our Site
     • Supplying Our service to you
     • Responding to communications from you
     • Supplying you with email communications, e.g. alerts, service information, renewal updates relating to your membership, or newsletters that you have subscribed to (you may unsubscribe or opt-out at any time by clicking on the unsubscribe link at the bottom of your newsletters
     • Market research
   • With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email or telephone or post with information, news and offers on Our services or products. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the Data Protection Act 1998 and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.

5. How and Where Do We Store Your Data?
   • We only keep your data for as long as We need to in order to use it as described above in section 4, and/or for as long as We have your permission to keep it.
   • Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.
   • Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.

6. Do We Share Your Data?
   • We may contract with third parties to supply products and services to you on Our behalf. These may include payment processing, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
   • We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.
   • In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.

7. What Happens If Our Business Changes Hands?
   • We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by users will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by Us.
   • In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted, you will not, however, be given the choice to have your data deleted or withheld from the new owner or controller.

8. How Can You Control Your Data?
   • When you submit information via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving email newsletters from Us which you may do by unsubscribing using the links provided in Our emails.

9. Your Right to Withhold Information
   • You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
   • You may restrict your internet browser’s use of Cookies. For more information, see section 11.

10. How Can You Access Your Data?

You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held) on payment of a small fee which will not exceed £1. Please contact Us for more details at [email protected].

11. Contacting Us

If you have any questions about Our Site or this Privacy Policy, please contact Us by email at [email protected]. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 10, above).

12. Changes to Our Privacy Policy

We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

Cookie Policy

This Cookie Policy explains how Gallerr, Inc. and our affiliates use cookies and similar technologies to recognise you when you visit our Websites including our associated mobile applications (Mobile Apps) owned and controlled by Gallerr. It explains what these technologies are and why we use them, as well as your rights to control our use of them.

What are 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, 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, Gallerr) 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 recognise your computer both when it visits the website in question and also 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. For example, Gallerr keeps track of the Websites and pages you visit within Gallerr, in order to determine what portion of the Gallerr Website is the most popular or most used. This data is used to deliver customized content and promotions within the Gallerr Website 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?

The specific types of first and third party cookies served through our Websites and the purposes they perform. For a list of the cookies used by Gallerr, see this page. These cookies include:

Essential website cookies: These cookies are strictly necessary to provide you with services available through our Websites, Subscription Service and Mobile Apps 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, Subscription Service and Mobile Apps but are non-essential to their use. However, without these cookies, certain functionality may become unavailable.

Analytics and customisation cookies: These cookies collect information that is used either in aggregate form to help us understand how our Websites, Subscription Service and Mobile Apps are being used or how effective our marketing campaigns are, or to help us customise our Websites for you.

Advertising cookies: These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests.

Social networking cookies: These cookies are used to enable you to share pages and content that you find interesting on our Websites, Subscription Service or Mobile Apps 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 links provided below.

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.

In addition, most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit http://www.aboutads.info/choices/ or http://www.youronlinechoices.com. You may opt out by clicking here: http://preferences.truste.com/ (or if located in the European Union, by clicking here: http://www.youronlinechoices.eu/). Please note this does not opt you out of being served advertising. You will continue to receive generic advertisments.

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.

What about other tracking technologies, like web beacons?

Cookies are not the only way to recognise or track visitors to a website. We employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage the Website by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user's computer hard drive, clear gifs are embedded invisibly on Web pages or in emails and are about the size of the period at the end of this sentence. We use clear gifs or pixels in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. We tie the information gathered by clear gifs in emails to our customers' Personal Information.

Do you use Flash cookies or Local Shared Objects?

The Adobe Flash Player (and similar applications) use technology to remember settings, preferences and usage similar to browser cookies but these are managed through a different interface than the one provided by your Web browser. This technology creates locally stored objects that are often referred to as "Flash cookies." Gallerr does not use Flash cookies. However, our customers of our software platform may create pages on the Gallerr platform that employ Adobe Flash cookies. Gallerr does not have access or control over our customers' Flash cookies, but you may access your Flash management tools from Adobe's web site directly here.

Do you serve targeted advertising?

Third parties may serve cookies on your computer or mobile device to serve advertising through our Websites. These companies may use information about your visits to this and other websites in order to provide relevant advertisements about goods and services that you may be interested in. They may also employ technology that is used to measure the effectiveness of advertisements. This can be accomplished by them using cookies or web beacons to collect information about your visits to this and other sites in order to provide relevant advertisements about goods and services of potential interest to you. The information collected through this process does not enable us or them to identify your name, contact details or other personally identifying details unless you choose to provide these.

How often will you update this Cookie Policy?

We may update this Cookie Policy from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal or regulatory reasons. Please therefore re-visit this Cookie Policy regularly to stay informed about our use of cookies and related technologies.

The date at the top of this Cookie Policy indicates when it was last updated.

Where can I get further information?

If you have any questions about our use of cookies or other technologies, please email us at [email protected].

Last updated 24^th May 2018