Privacy Policy

Introduction

The purpose of this privacy policy (“Privacy Policy”) is to describe how Wisdom Planet Inc., (“Wisdom Planet”, “us”, “we” or “our”) collects, uses, maintains and shares information about you (“User” or “you”) through online interfaces (e.g., websites and mobile applications) owned and controlled by us, including Clear.Skin and its mobile applications  (collectively referred to herein as “Clear.Skin”). Capitalized terms not defined herein shall have the same meaning as those ascribed to them in the Terms of Use.

We recognize the importance of your privacy and we are committed to ensuring that you are aware of how your information is being used. Please read this notice carefully to understand what we do. Your use of Clear.Skin is also governed by our Terms of Use. If you do not understand any aspects of our Privacy Policy, please feel free to contact us at support@wisdomtimes.com. You are free to use Clear.Skin only if you agree with our policies and practices encapsulated in this Privacy Policy and the Terms of Use. Your use or access of Clear.Skin shall constitute your agreement to this Privacy Policy.

Applicability of the Policy

This policy shall apply to all information Wisdom Planet collects on Clear.Skin including but not limited to any information you upload, emails that you exchange with Wisdom Planet and other Users of Clear.Skin and any information submitted by you to Wisdom Planet. The policy does not apply to, nor does Wisdom Planet take any responsibility for, any information that is collected by any third party either using Clear.Skin or through any links on Clear.Skin or through any advertisements on Clear.Skin.

Nature of Information Collected and Manner of Collection

In the use of Clear.Skin, as you navigate through Clear.Skin, Wisdom Planet may collect different types of information. This information could be either “Personally Identifiable Information” (that is, information that could be used to identify you such as, your name, email address etc.) or “Non-Personal Information” (that is, information that cannot be used to identify you such as the webpages that you have viewed and your usage patterns and which may include information in connection with your participation in courses, including but not limited to your interaction with the course instructor and other users, comments that are posted on course forums, answers/essays that are submitted by you to satisfy course requirements) or “Device Information”(that is, information that is automatically collected about the type of device that is used when the Clear.Skin app is downloaded or the operating system version of Clear.Skin is used, so Clear.Skin know the best application version to provide you with. Clear.Skin neither asks you for access, nor tracks any location based information from your mobile device at any time while downloading or using Clear.Skin).

Wisdom Planet may also collect information about searches you have done on Clear.Skin, advertisements or third party links that you have visited, any emails or other correspondence you have exchanged on Clear.Skin or with Wisdom Planet.

You are responsible for ensuring the accuracy of the Personally Identifiable Information you submit to Wisdom Planet. Inaccurate information may affect your ability to use Clear.Skin, the information you receive when using Clear.Skin, and our ability to contact you. For example, your email address should be kept current because that is one of the primary manners in which we communicate with you.

You understand that the information collected by Wisdom Planet, may be collected directly or through tracking of your usage of Clear.Skin. The usage details may include IP addresses, details of your computer equipment, browser, location, connections, any information that Wisdom Planet may collect through the use of cookies and other tracking technologies.  The collection of data may in most cases be automatic.

“Cookies” are files that would be placed in your system’s hard drive and are intended to improve your experience of Clear.Skin, by enabling Wisdom Planet to track your usage and preference, advertisement and links that you visit and other usage data. Most cookies Wisdom Planet uses are limited to a session, which mean they will be automatically deleted when your session closes.  You may decline these cookies by changing your browser settings, if permitted, however do note that this may impact certain features of Clear.Skin or your experience in using Clear.Skin

We may use cookies for the following reasons and purposes:

1. To provide the service you have asked for. Some cookies are essential so you can navigate through the website and use its features. Without these cookies, we would not be able to provide the services you’ve requested. For example, some cookies allow us to identify subscribers and ensure they can access the subscription only pages. If a subscriber opts to disable these cookies, the user will not be able to access all of the content that a subscription entitles them to. These cookies don’t gather information about you that could be used for marketing or remembering where you’ve been on the internet. Essential cookies keep you logged in during your visit.
2. To improve your browsing experience. These cookies allow the website to remember choices you make, such as your language or region and they provide improved features. These cookies will help remembering your preferences and settings, including marketing preferences, remembering if you’ve filled in certain forms, so you’re not asked to do it again, remembering if you’ve been to the website before and restricting the number of times you’re shown a particular advertisement. We might also use these cookies to highlight website services that we think will be of interest to you based on your usage of the website.
3. Analytics. To improve your experience on our website, we like to keep track of what pages and links are popular and which ones don’t get used so much to help us keep our website relevant and up to date. It’s also very useful to be able to identify trends of how people navigate (find their way through) our website and if they get error messages from web pages. This group of cookies, often called “analytics cookies” are used to gather this information. These cookies don’t collect information that identifies you. The information collected is anonymous and is grouped with the information from everyone else’s cookies. We can then see the overall patterns of usage rather than any one person’s activity.
4. To show advertising that is relevant to your interests. We may sell space on our website to advertisers. The resulting ads often contain cookies. These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with our permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers.

Most browsers allow you to turn off cookies. To do this, look at the “help” menu on your browser. Switching off cookies may restrict your use of the website and/or delay or affect the way in which it operates.

 Note: Advertisements on Clear.Skin may be posted by third-party advertisers, and such third parties may use cookies and other automatic tracking technologies to collect information about you, including but not limited to web behavioral information and patterns. Wisdom Planet neither controls nor takes any responsibility for such third parties, their collection and use of information or their tracking technologies or how they may be used.

You also may provide information to be published or displayed or posted on Clear.Skin, or transmitted to other Users of Clear.Skin or third parties. Any such information is posted or transmitted to other parties at your own risk and will not be monitored by Wisdom Planet for its content or compliance. Please be aware that Wisdom Planet cannot control the actions of other Users of Clear.Skin with whom you may choose to share information with.

Use of Your Information

The information that we collect on Clear.Skin will be used for the purposes of operating Clear.Skin, facilitating your use of Clear.Skin, studying user behavior and for other business purposes of Wisdom Planet including, but not limited to:

(i) Ensuring the content from Wisdom Planet is presented in the most effective manner for you and for your computer and mobile device;

(ii) To provide you with information, products or Services that you request from us which we feel may interest you, where you have consented to be contacted for such purposes;

(iii) To carry out obligations arising from any contracts entered into between you and us, including for billing and collection;

(iv) To notify you about changes to Wisdom Planet.

(v) In any other way we may describe when you provide the information.

Except as otherwise provided herein, no Personally Identifiable Information will be disclosed or shared with any third party without your express consent. For the purposes of this policy, Personally Identifiable Information shall mean name; age; gender; bank account information; telephone numbers; location data; email addresses; payment, billing or shipping information.

Please do not include any personal information, Personally Identifiable Information or sensitive personal information unless specifically requested by Wisdom Planet as part of the registration or other applicable processes. If Wisdom Planet determines that any information you have provided or uploaded violates the terms of this Privacy Policy, Wisdom Planet has the right, in its absolute discretion, to delete or destroy such information without incurring any liability to you.

Clear.Skin will not publish, sell or rent your personal information or Personally Identifiable Information to third parties for their marketing purposes without your explicit consent.

Clear.Skin may also use the information for analytical purposes, including but not limited to assessing usage data, usage patterns, estimate audience sizes and other similar activities.

You agree that your personal information may be used to contact you and deliver information or targeted advertisements, administrative notices and any other communication relevant to your use of Clear.Skin. If you do not wish to receive these communications, you can at any time change your profile settings.

Disclosure of Your information

We consider the confidentiality and security of your information to be of the utmost importance. We will use industry standard physical, technical and administrative security measures to keep your User Information confidential and secure and will not share it with third parties, except as otherwise provided in this Privacy Policy, or unless we have good faith belief that such disclosure is necessary in special cases, such as a physical threat to you or others. Because the Internet is not a 100% secure environment we cannot guarantee the security of Personally Identifiable Information, and there is some risk that an unauthorized third party may find a way to circumvent our security systems or that transmission of your information over the Internet will be intercepted. It is your responsibility to protect the security of your login information. Please note that e-mails and other communications you send to us through Clear.Skin are not encrypted.

We may disclose your User Information to our agents, employees, third party advertisers, subsidiaries and affiliates, or to other third party service providers who require the information only for the purposes of operating and maintaining Clear.Skin and for facilitating your use of our Services offered on Clear.Skin.

We will comply with requests and directions of all governmental, law enforcement or regulatory authorities, which it believes in good faith to be in accordance with any applicable law. Such compliance may include providing information of Users, Personally Identifiable Information or any other information available to such agency or authority.  By providing any information on Clear.Skin, you consent to Wisdom Planet providing such information to any governmental, law enforcement or regulatory authorities, upon an order to do so under applicable law, who exercise jurisdiction over Wisdom Planet and Clear.Skin.

Data Retention

Wisdom Planet may retain User information, whether Personally Identifiable, Non- Personal or Device Information, for such length of time as may be required in order for Wisdom Planet to provide the concerned User with Services, comply with legal obligations, resolve any disputes that may arise, enforce its rights arising out of agreements with Users, and/or for such period as may be required by legislation/orders of regulatory authorities to which Wisdom Planet is subject.

California Privacy Rights

Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g. requests made in 2014 will receive information regarding 2013 sharing activities).

To obtain this information, please send an email message to support@wisdomtimes.com with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

International Privacy Rights

Wisdom Planet’s websites and mobile applications are operated and managed on servers that may be located and operated in different jurisdictions. By using and accessing Clear.Skin, you consent to the transfer to and processing of personal information on servers that may be located in a jurisdiction different from where you are located, and that the protection of such information may be different than required under the laws of your residence or location.

Data Security

The information that you provide, subject to disclosure in accordance with this Privacy Policy and Terms of Use, shall be maintained in a safe and secure manner.  Wisdom Planet’s databases and information are stored on secure servers with appropriate firewalls owned by Wisdom Planet or by third parties.

As a User of Clear.Skin, you have the responsibility to ensure data security. You should use Clear.Skin in a responsible manner. Do not share your username or password with any person. You are solely responsible for all acts done under the username you are registered under.

Given the nature of internet transactions, Wisdom Planet does not take any responsibility for the transmission of information including the User Information you provide to Clear.Skin. Any transmission of your User Information on the internet is done at your risk. Wisdom Planet does not take any responsibility for you or any third party circumventing the privacy settings or security measures contained on Clear.Skin.

While Wisdom Planet will use all reasonable efforts to ensure that your personal information and other information submitted by you is safe and secure, it offers no representation, warranties or other assurances that the security measures are adequate, safe, fool proof or impenetrable.

Accessing and Updating Your Information

You can change, alter of otherwise modify or update your information at any time by accessing Clear.Skin using your registered username and accessing your user account.

You may also change and/or delete any of the information you have submitted. Do note however, Wisdom Planet reserves the rights to save any usage information and you are not entitled to seek the deletion of the same.

Wisdom Planet at its sole discretion may permit or deny the change of any information, if it is believed the same is required to observe applicable laws.

Age Restrictions

Wisdom Planet is not directed to children under the age of 16. We do not knowingly collect any personal information about children under the age of 16. If we obtain actual knowledge that we have collected personal information about a child under the age of 16, that information will be promptly deleted from our database, unless it is necessary to retain it for legal purposes.

If a parent believes that his or her child has submitted personal information to us, he or she can contact us via e-mail. We will promptly delete the information upon learning that it relates to a child under the age of 16. Please note that it is possible some of this information may remain archived in web logs and back-up archives after we delete the information from our active database.

EU Users’ Rights

This section of our Privacy Policy applies to the users of our platform in the EU. We would like to inform you about your EU General Data Protection Regulation (GDPR) rights and how we safeguard them.

Your GDPR rights to be informed, to access, rectify, erase or restrict the processing of your personal information. You have the right to receive free information about what personal data we have obtained about you, where it is stored, for how long, for what purposes it is used, to whom it was disclosed. You have the right to require that we, without undue delay, rectify of inaccurate personal data concerning you. That means you can request we change your personal data in our records, or have you incomplete personal data completed. You have the “right to be forgotten,” i.e. to have us delete your personal information, without undue delay, if the data is no longer necessary in relation to the purposes for which it was collected. However, GDPR gives us the right to refuse erasure if we can demonstrate compelling legitimate grounds for keeping your information.

GDPR gives you the right to restrict processing if any of the following applies:

(i) If you contest the accuracy of your personal data, we will restrict processing it for a period enabling us to verify its accuracy.

(ii) The processing is unlawful and you oppose its erasure and request instead the restriction of its use.

(iii) We no longer need your personal data for the purposes of the processing, but you require us to restrict processing for the establishment, exercise or defense of legal claims.

(iv) You have objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether our legitimate grounds override yours.

1. Right to data portability. Upon request, we will provide you your personal data in our possession, in a structured, commonly used and machine-readable format. You have the right to transmit that data to another controller if doing so does not adversely affect the rights and freedoms of others.
2. Right to object. You can object, on grounds relating your particular situation, at any time, to processing of your personal information, if based on point (e) or (f) of Article 6(1) of the GDPR.  We will then have to stop processing, unless we can demonstrate compelling legitimate grounds for the processing. If you object to the processing for direct marketing purposes, we will have to stop processing for these purposes.
3. Right to withdraw consent. GDPR grants you the right to withdraw your earlier given consent, if any, to processing of your personal data at any time.
4. Rights related to automated decision making. As a responsible business, we do not rely on any automated decision making, such as profiling.

Amendments to the Privacy Policy

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new Last Updated date stated at the bottom of this page. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its Last Updated date onwards. Major changes to our Privacy Policy or the purposes for which we process your information Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website. We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.

Terms of Use

This Privacy policy shall form a part of the Terms of Use.

Accessing and Correcting Your Personal Information

Please send us an e-mail to support@wisdomtimes.com to request access to, correct or delete any personal information that you have provided to us or to ask questions about this Privacy Policy. We reserve the right to refuse a request if we believe it would violate any law or cause the information to be incorrect. You can edit or delete your own information in your account settings. You can also contact us by mail at the following address:

 Our full details are:

 Full name of legal entity: Wisdom Planet, Inc.,

 Email address: support@wisdomtimes.com

 Postal address: PO Box 41894, Sacramento, CA 95841, USA

Last Updated: May 25, 2018