Privacy Policy

Introduction

Welcome to Winning Feathers, a web-based service that instructs the English language to young learners (“Service”). (Available at www.winningfeathers.com, “Site”). Winning Feathers, LLC (“Winning Feathers”, “Company”, “we” or “us”) respects your privacy and has created this Privacy Policy to explain what information about you we collect through our Site or Service and how we use and disclose such information. This Privacy Policy applies to all information we collect or receive from you.

How to reach us

If you have any questions regarding this Privacy Policy, or if you would like to contact Winning Feathers for any other reason, please email info@winningfeathers.com

Special note to international users

If you are a user accessing the Service from outside of the United States, such as the European Union (EU) or any other country or region, please note that you are transferring your Personal Information to the United States which may not have the same data protection laws as the laws governing personal data collection, use, and disclosure in the EU and other countries or regions. By providing your Personal Information (defined below) to us through our Site or Service, you consent to:

  • Collection, use and disclosure of your Personal Information in accordance with the Privacy Policy; and
  • The transfer of your Personal Information to and storage of such information in the United States, and process of such information globally.

You further agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of the United States and the adjudication of any disputes arising in connection with this Privacy Policy will be submitted and resolved through binding arbitration with JAMS in accordance with the current applicable arbitration rules.

Information we collect

“Personal Information” means information that alone or when in combination with other information may be used to readily identify, contact, or locate you, or issue payment or tax information to you, such as your name, address, email address, phone number, social security number or bank account information.

We do not consider Personal Information to include information that has been aggregated and/or de-identified so that it does not allow a third party to easily identify a specific individual.

Registration information

When you create your Winning Feathers Applicant Account (for prospective coaches) or Coach Account (for coaches), you will be required to provide certain personal information, which may include your first and last name, a user name (which can be your email address), a password, the country in which you reside, your gender, your time zone, your current job, educational degrees and related work background (including but not limited to whether you ever taught in a U.S. school and information about that school) or other information. If you are a coach, we also collect and store any additional information that you provide to us in your profile, which may include: your time availability, your location and address, pictures and videos you choose to post, your phone number, and your Skype/Zoom account, etc.

Interview Recording

For prospective coaches, we may conduct telephone and video interviews, including mock classes, and we may record such interviews and mock classes. The purpose of the recording is to expedite the interview and facilitate the evaluation processes. The recorded audios and videos will be kept strictly confidential in our server in the United States for a commercially reasonable period of time and will be for our internal use only. We will not disclose the recorded audios and videos to the public or share the recorded videos with any third parties without your express consent unless only for internal use. BY CREATING AN APPLICANT ACCOUNT AND AGREEING TO INTERVIEW WITH US, YOU CONSENT TO OUR RECORDING THE TELEPHONE AND VIDEO INTERVIEW AND STORING THE RECORDINGS IN THE UNITED STATES.

Testimonials

Winning Feathers may post customers’ testimonials on our Site, which may contain Personal Information from our customers. Once you accept the Winning Feathers contract, you give your consent to Winning Feathers to publish any testimonial, post, comments, and any other representations you have made through our Site or our Service, along with your name if provided.

Automatic Collection of Data

Cookies: when you visit our Site, either directly or by clicking through hyperlinks appearing on third party websites, or use one or more of our Services, we may use automatic data collection technologies to collect certain information about your device, browsing actions, and patterns, which may include:

Details of your visits to our website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the website. Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically helps us to improve our Site or Service and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns;
  • Store information about your preferences, allowing us to customize our Site according to your individual interests;
  • Speed up your searches;
  • Recognize when you return to our website; and
  • Customize your experience to better match your interests and preferences or simply facilitate your signing-in to use the Service.

Some of the industry-wide technologies include cookies, flash cookies, or beacons. A cookie stores certain information on your computer. Most browsers will allow you to erase cookies from your computer hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. Please refer to your browser instructions or help screen to learn more about these functions. By allowing your browser settings to accept cookies from this Site or Service, you consent to our placement of cookies on your personal computer and/or mobile device. However, users of our Site and Service can set their browsers to accept or reject all, or certain, cookies. Like most websites, if you turn your cookies off, some of our services may not function properly. However, you can still communicate with us by e-mail at privacy@winningfeathers.com. If you do not wish to share such automatically collected information with Winning Feathers, then you should take steps to limit the passive collection of data about your activities on our Site, for example, by changing your browser settings to disable cookies. We reserve the right to use and disclose any non-Personal Information, as well as any other non-Personal Information we collect, with our advertisers and other third parties at our discretion.

Social media features and widgets

Our Site may include social media features and widgets, such as the Facebook “Like” and “Share” buttons. These features may collect your IP address, the URL of the page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policies of their providers. You should review the privacy policies or terms of these providers.

What we do with your information

In general, the Personal Information we collect is used to (1) improve our services and enhance your experience with Winning Feathers, (2) enable us to provide a safer community for all of our Registered Users, and (3) communicate with us. We may use your Personal Information to register and service your account, update your coach profile, contact you for questions and feedback, enable students to search for you, verify information you provide us, help protect the safety and integrity of the Site and Winning Feathers users, and provide targeted promotional messages or content on the Site, via email (for which you have an option to opt-out) or other advertisements on Winning Feathers or third party websites.

Children

The Children’s Online Privacy Protection Act of 1998 and its rules (collectively, “COPPA”) require us to inform parents and legal guardians (as used in this policy, “parents”) about our practices for collecting, using, and disclosing personal information from children under the age of 13 (“children”). It also requires us to obtain verifiable consent from a child’s parent for certain collection, use, and disclosure of the child’s personal information.

This policy notifies parents of:

  • The types of information we may collect from children.
  • How we use the information we collect.
  • Our practices for disclosing that information.
  • Our practices for notifying and obtaining parents’ consent when we collect personal information from children, including how a parent may revoke consent.
  • All operators that collect or maintain information from children through this Winning Feathers website.

This policy only applies to children under the age of 13 and supplements our general privacy policy. Only our general privacy policy applies to teens and adults.

Terms that are defined in the general privacy policy have the same meanings as used in this Privacy Policy for Children Under the Age of 13.

Information We Collect from Children

Children can access many parts of the Site and its content and use many of its features without providing us with personal information. However, some content and features are available only to registered users. In addition, we use certain technologies, such as cookies, to automatically collect information from our users (including children) when they visit or use the Site.

We only collect as much information about a child as is reasonably necessary for the child to participate in an activity, and we do not condition his or her participation on the disclosure of more personal information than is reasonably necessary.

Information We Collect Directly

A child must provide us with the following information to register with this website: the child’s first name, last name, birth date, email address, and a parent’s email address. We also require the child to create a member name and password. We may request additional information from your child, but this information is optional. We specify whether information is required or optional when we request it.

We may enable registered users to communicate with others on or through this Website through chat, email, and posting to public areas of the Site (“Social Features”). The nature of these features allows children to disclose personal information about themselves. We do not monitor or review this content before it is posted, and we do not control the actions of third parties with whom your child shares his or her information. We encourage parents to educate their children about safe internet use and to monitor their children’s use of social features.

Automatic Information Collection and Tracking

We use technology to automatically collect information from our users, including children, when they access and navigate through the Site and use certain of its features. The information we collect through these technologies may include:

  • One or more persistent identifiers that can be used to recognize a user over time and across different websites and online services.
  • Information that identifies a device’s location (geolocation information).

We also may combine non-personal information we collect through these technologies with personal information about you or your child that we collect online.

For information about our automatic information collection practices, including how you can opt out of certain information collection, see our general Privacy Policy.

How We Use Your Child’s Information

We use the personal information we collect from your child to:

  • register him or her with the Site;
  • communicate with him or her about activities or features of the Site that may be of interest;
  • track his or her performance in activities;
  • to facilitate educational goals for students.

We use the information we collect automatically through technology (see Automatic Collection of Data) and other non-personal information we collect to improve our Site and to deliver a better and more personalized experience by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about the child’s preferences, allowing us to customize the content according to individual interests.
  • Speed up your searches.

We use geolocation information we collect to improve our Site and deliver a better and more personalized experience.

Our Practices for Disclosing Children’s Information

We do not share, sell, rent, or transfer children’s personal information other than as described in this policy.

We may disclose aggregated information about many of our users, and information that does not identify any individual or device. In addition, we may disclose children’s personal information:

  • To third parties we use to support the internal operations of our Site and who are bound by contractual or other obligations to use the information only for such purpose and to keep the information confidential.
  • If we are required to do so by law or legal process, such as to comply with any court order or subpoena or to respond to any government or regulatory request.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Winning Feathers, our customers or others, including to:
    • protect the safety of a child;
    • protect the safety and security of the Site; or
    • enable us to take precautions against liability.
  • To law enforcement agencies or for an investigation related to public safety.
  • For certain promotional purposes.

In addition, if Winning Feathers is involved in a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Winning Feathers’ assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding or event, we may transfer the personal information we have collected or maintain to the buyer or other successor.

Social Features

The Site may offer social features, including instant messaging, chat, email, and posting on message boards that enable children communicate with others on our through the Site. We do not control the types of information your child can send or post through them. We encourage parents to educate their children about safety online and to carefully monitor their children’s use of social features to ensure they do not disclose their personal information through them.

Accessing and Correcting Your Child’s Personal Information

At any time, you may review the child’s personal information maintained by us, require us to correct or delete the personal information, and/or refuse to permit us from further collecting or using the child’s information.

You can review, change, or delete your child’s personal information by:

Sending us an email at info@winningfeathers.com. To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections.

Operators That Collect or Maintain Information from Children

A list of all operators that may collect or maintain personal information from children through the Site is available here.

Please direct your inquiries about any operator’s privacy practices and use of children’s information to the operator at its contact information provided.

Background Check

In order to promote the safety and integrity of the Site and Service, when you create your Student Account or Coach Account, you authorize Winning Feathers to utilize third party service providers to use your Personal Information to scan on an ongoing basis a variety of sources, which may include, but are not limited to, national criminal databases, sex offender registries, certain media streams, terrorist watch lists, criminal and fugitive watch lists, fraud watch lists, law enforcement reports, and other data to assist us in verifying the information you provide us (such as your name, address, email address, etc.) (the “Verification Check”). The results of any Verification Checks will be made available to Winning Feathers. For the legitimate business purpose of protecting the safety and integrity of the website and Winning Feathers users, you also authorize Winning Feathers to utilize a third party consumer reporting agency to use your Personal Information to run periodic background checks on you when you register with Winning Feathers.

Sharing with Affiliates

Your information collected through the Winning Feathers main website, its affiliate website, or any of its Services will be stored in Winning Feathers ‘s database, which is only accessible through the use of a Virtual Private Network (VPN) or similar means with access restricted to only key members in the Company. Following termination or deactivation of your account, Winning Feathers, its affiliated companies, or its service providers may retain information associated with your profile for a commercially reasonable period of time for backup, archival, audit, or other business purposes permitted by laws.

Sharing with third parties

We may share your information with third parties who provide services on our behalf, which may include website hosting, bank payment, advertising (including but not limited to retargeted advertising), referral (including but not limited to providing information to referring parties) and other services of an administrative nature (including but not limited to the coordination of events). We may also share your information with third party companies and/or contractors that we partner or contract with to provide certain services or reach-outs to you in connection with the Service (or signing up to use the Service). These partners’ collection and use of information is subject to their privacy policies and other terms. You should review such privacy policies and terms.

Sharing with registered students and parents

If you are a coach, in order to increase your class booking rate, we share with registered users (e.g., students and their parents) certain information that is included in your profile, which may include your contact information, your name (first name and first letter of last name), your location (city, state/province, country), your profile picture, your gender, your age, or other information. The more information you share, the more likely you will find students. We may also include in your profile any Company reviews you have posted on our Site and share such information. If you post information in a Winning Feathers online forum, that information may be viewed by any Site Visitor or Registered User who accesses the forum.

Links to other sites

Our Site contains links to third party websites (any URLs that do not end in winningfeathers.com) that are not owned or controlled by us, including the websites of our content providers or affiliates. These third-party websites may send their own cookies to you, and collect data or solicit personal information from you. Winning Feathers is not responsible for the content or privacy practices of these third-party websites. Winning Feathers encourages you to review the privacy practices of those websites before providing any personal data to them. While Winning Feathers strives to protect our users’ Personal Information and privacy, we cannot guarantee the security and privacy of any information you disclose at these third-party websites. and you do so at your own risk. Please learn about the privacy and security practices and policies of the third-party websites before providing them with your Personal Information.

Not to use for profit (rent or sell)

Except as otherwise described in this Privacy Policy, Winning Feathers will not disclose, share, sell or rent Personal Information collected on our Site or Service to third-party organizations for their direct marketing or promotional use without your consent, except that it may do so as part of a specific program or feature for which you will be notified and have the ability to opt-out. Specifically, we do not share your bank account information with Affiliate Sites or any other third parties, except for the purpose of making payments for coaches.

As required by law

We may access, preserve, and disclose your Personal Information or other account information if we believe that doing so is required or appropriate to (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; (c) protect your, our or others’ rights, property, or safety; or (d) as otherwise required by law.

Merger and acquisition

If we sell or otherwise transfer part or the whole of Winning Feathers business and/or our assets to another organization in a merger, acquisition, or other corporate restructuring transaction, or we are involved in a bankruptcy, dissolution or liquidation, your information such as name and email address and any other information collected through our Site or Service may be among the items sold or transferred. You will be notified of any such change in corporate ownership or use of your Personal Information, and of your choices regarding the information.

Updating or deleting your registration information

As part of the requirements for your use of our Site or Service, you are responsible for updating your submitted registration information so that it is current, complete and accurate. You can update this information by logging into your account and accessing your account settings. If you would like to remove some of the Personal Information you have posted on the Site, such as information you posted in profiles, you may do so by editing or deleting that item. To request removal of other Personal Information you have voluntarily posted on our Site, such as information you may have posted in online group forums, you can Winning Feathers at privacy@winningfeathers.com. We strive to accommodate your request, though we cannot guarantee that the information can be successfully removed in all cases.

Additional Notice for California Consumers

This portion of our Privacy Policy applies to California consumers only.

Personal Information Collected on California Consumers in the Last Twelve Months

We collect information from users, as described in our Privacy Policy. The “Personal Information,” as defined in California Civil Code § 1798.140(o), we have obtained on California residents within the last twelve months includes the following:

  • Identifiers such as a real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers.
  • Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.
  • Geolocation data (excluding real time GPS information).
  • Audio, electronic, visual, thermal, olfactory, or similar information.
  • Professional or employment-related information.
  • Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).
  • Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Our Use of Personal Information for Business Purposes in the Last Twelve Months

We use the Personal Information we collect, identified in each of the above categories, for the business purposes disclosed within the Privacy Policy. These business purposes include the following:

  • Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
  • Debugging to identify and repair errors that impair existing intended functionality.
  • Short-term, transient use, provided the personal information that is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
  • Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
  • Undertaking internal research for technological development and demonstration.
  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.
  • Certain limited marketing purposes.

Sharing of Personal Information in the Last Twelve Months

Disclosures of Personal Information on California Consumers for Business Purposes: Within the last twelve months, we have disclosed Personal Information identified in the above categories only (i) for exempt activities, as part of a business-to-business transaction, (ii) at your express request, or (iii) for our business purposes. For more information on the service providers with whom we share information, please see Our Disclosure of Your Personal Information and Other Information.

California Rights and Choices

If you are a California resident, you have certain legal rights related to your Personal Information. Except as otherwise provided by applicable law, you may exercise the following rights for purposes of the Personal Information covered by our Privacy Policy.

  • Right to Know/Portability
    You have the right to request that we disclose to you certain information about Personal Information we collected about you within the past twelve months. Once we confirm your verifiable request, we will disclose to you:

    • the categories of Personal Information we have collected about you;
    • the categories of sources from which the Personal Information is collected;
    • our business or commercial purpose for collecting Personal Information;
    • the categories of third parties with whom we share Personal Information; and
    • the specific pieces of information we have collected about you.
  • Right to Opt Out
    We do not offer a right to opt out because we have not sold any Personal Information described in this Privacy Policy to third parties within the previous twelve months and will not sell Personal Information within the meaning of the CCPA.
  • Right to Deletion
    You have the right to request deletion of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we confirm your verifiable request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
    We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

    • complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
    • detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
    • debug products to identify and repair errors that impair existing intended functionality;
    • exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
    • comply with the California Electronic Communications Privacy Act;
    • enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
    • comply with a legal obligation; or
    • make other internal and lawful uses of that information that are compatible with the context in which you provided it.
  • Right to Non-Discrimination for Exercise of a California Privacy Rights
    We will not discriminate against you because you exercise any of the above rights, or any other rights under the CCPA. Specifically, if you exercise your Rights, we will not deny you Services, charge you different prices or rates for Services or provide you a different level or quality of Services.
  • How to Submit A Request
    You may submit a request to exercise the rights listed above by:

    • emailing us at info@winningfeathers.com.
    • In your request, please include (1) full name used to create your account; (2) email with which you created your account; (3) phone number in case we need to contact you to securely verify your request; (4) whether you are requesting how your information is used and/or to delete your personal information.
  • Verifiable Request
    As required under applicable law, we take steps to verify your identity before responding to your request. We may require you to provide information sufficient enough to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative. We may limit our response to your exercise of the above rights as permitted under applicable law.
  • Agent Authorization and Disability Access
    You may designate an authorized agent to make a request on your behalf. As permitted by law, we may require additional verification in response to a request even if you choose to use an agent. You may also make a verifiable consumer request on behalf of your minor child. To access this Privacy Policy by an alternative method, please contact us at privacy@winningfeathers.com.
  • Right to Opt-Out and Right to Opt-In
    Please note we do not sell Personal Information of California Consumers regardless of your age. If you are 16 years of age or older, you have the right to direct us to not sell your Personal Information at any time (the “right to opt out”). We do not sell the Personal Information of consumers we know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt in to Personal Information sales may opt out of future sales at any time.
  • Responding to Requests
    We will confirm receipt of your request within 10 days from receipt, and provide information about how we will process the request, our verification process, and when you can anticipate a response to the request. We will use commercially reasonable efforts to honor your request within 45 days from receipt. If additional time is needed, we will notify you of the same, along with an explanation and anticipated timeline for the extension which shall not exceed 90 days from the date of receipt.

Other California Privacy Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to: info@winningfeathers.com.

Do Not Track

Your “Do Not Track” Browser Setting: some web browsers incorporate a “Do Not Track” feature (DNT) that signals to the websites that you visit that you do not want to have your online activity tracked. Many websites and applications, including our Site, do not currently respond to web browser DNT signals because such signals are not yet uniform. For more information about DNT signals, please visit http://allaboutdnt.com.

Amendments

By using our Site or Service, you agree to the terms in this Privacy Policy, which may be amended from time to time. We reserve the right to make changes to this Privacy Policy. We will provide notice to you of any material changes by any reasonable means including sending an email to the most recently updated address in your account and/or posting such notice and the amended policy on the Site. Your continued use of our Site or Service following the changes to this Privacy Policy will mean that you accept and agree to the changes and that any information collected or provided after such change will be governed by the updated Privacy Policy.

Security

Winning Feathers is dedicated to protecting your Personal Information and takes reasonable security measures to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional access, use or disclosure of your information.

As a user of our Site or Service, please remember to sign out of your Winning Feathers Account, and close your browser window whenever you leave your computer. This is to ensure that others cannot access your account or Personal Information. To help protect your Winning Feathers Account information, please keep your password secure and do not divulge your password to anyone. We suggest that you pick a non-obvious password that mixes numbers and letters. Ultimately, you are responsible for maintaining the secrecy of your passwords and any Winning Feathers Account information, and we are not responsible for the unauthorized use by third parties of information you post or otherwise make available publicly.

We welcome your comments and questions on this Privacy Policy. You may reach out to our team by sending us an email to info@winningfeathers.com.

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