PRIVACY AND COOKIES NOTICE

Last updated: 11 October 2021

ABOUT THIS PRIVACY AND COOKIES NOTICE
- The website www.astotz.com (the Site), its sub-domains (e.g., academy.astotz.com), and related domains (e.g., astotz.kartra.com) are operated by LifeFORCE Co., Ltd. (“we”, “us”, “our”), a company incorporated in Thailand under company number 0105553063468. Our registered office is at Maneeya Center, 518/5 Ploenchit Road, Lumpini, Pathumwan, Bangkok, Thailand, 10330.
- We are committed to protecting your privacy and complying with our data protection obligations under the Data Protection Act 2018 (the DPA 2018), the General Data Protection Regulation 2016/679 (the GDPR) and any other applicable Thai legislation (together, Data Protection Law).
- When you interact with us or use the Site, we act as the data controller of your personal data. This means that we are responsible for processing your personal data and deciding how to use it. This privacy and cookies notice explains the types of personal data we may collect about you when you interact with us, why we collect it, what we use it for and what rights you have over that data. Personal data is any information about an identifiable person. Processing is anything we do with your personal data, including using, storing, sharing and deleting it.
- This notice was last updated on the date shown at the top. We may change this notice at any time by posting an updated version on the Site and will make reasonable efforts to bring any material changes to your attention. You may wish to check it before using the Site as any changes will be effective from the date that they are made.
CONTACT INFORMATION
- If you have any concerns or would like further information about our use of data or this notice in general, you can contact Alexander Wetterling at Maneeya Center, 518/5 Ploenchit Road, Lumpini, Pathumwan, Bangkok, Thailand, 10330.
WHAT INFORMATION DO WE COLLECT?
- We collect, store and use the types of personal data set out in the table at the end of this notice.
HOW WILL WE USE YOUR PERSONAL DATA?
- We will use your personal data for the purposes set out in the table at the end of this notice.
HOW DO WE SHARE YOUR PERSONAL DATA?
- When we share personal data, we do so in accordance with Data Protection law. We may share certain personal data:
  - with group, associated or affiliated companies including A. Stotz Academy Ltd., For internal administrative purposes.;
  - with employees, contractors, consultants or advisers, For purposes of customer service, sales, and for general commercial purposes..;
  - with government or quasi-governmental organisations, law enforcement and other regulatory authorities or third parties when required or permitted by law, including but not limited to in response to court orders, for the prevention and detection of crime and to protect intellectual property and any other legal rights;
  - if the Company or part of the business is sold, transferred or integrated with another business, with our advisers, a prospective purchaser, a prospective purchaser’s advisers or the new owner of the Company to facilitate the process; and
- We may also provide third parties with aggregated but anonymised information and analytics about our customers. Before we do so we will make sure that it does not identify you.
USE OF COOKIES AND SIMILAR TECHNOLOGIES
- We and our third-party service providers use cookies and similar technologies to collect information about, and relevant to, your usage of the Site. Cookies are small text files that are stored on your computer when you visit the Site. It is standard practice to use cookies to make your experience better when using a website.
- We use the following categories of cookies and similar technologies on this Site:
  - Strictly necessary cookies: These cookies are essential to enable you to move around the Site and use its features. Without these cookies, services you have asked for (such as remembering your login details or the items you placed in your basket) cannot be provided.
  - Analytics cookies: These cookies collect information about how you use the Site, for instance which pages you go to most often, what searches you perform and if you get error messages from web pages. Information these cookies collect can be used to improve how the Site works.
  - Security cookies: These cookies form part of our security features, for example, by helping us detect malicious activity or violations of our terms of use.
  - Targeting or advertising cookies: These cookies record your visit to the Site, the pages you have visited and the links you have followed. We use this information to make our Site and the advertising displayed on it more relevant to your interests. [We may also share this information with third parties for this purpose.
- When you visit the Site for the first time (and periodically after that), we will request your consent to the setting of all cookies other than strictly necessary cookies.
- You can delete existing cookies and disable some or all types of cookies in future if you wish. To disable some or all types of cookies, you will have to change the settings on your browser. If you change your mind, you can enable cookies again at any time. Disabling cookies on your browser may stop the Site from working properly.
- To find out more about cookies please visit allaboutcookies.org.
THIRD PARTY LINKS
- This Site contains links to other websites over which we have no control. We are not responsible for and do not review or endorse the privacy policies or practices of other Sites which you choose to access from this Site. We encourage you to review the privacy policies of those other Sites, so you can understand how they collect, use and share your personal information.
YOUR RIGHTS
- We respect your rights to privacy and will respond to requests for access or control over information about you in accordance with Data Protection Law. We may require you to verify your identity before we take any action.
- Depending on the reason we have your personal data, you have a right to:
  - access the personal information we hold about you (commonly known as subject access);
  - request that we correct or complete personal information we hold about you that is inaccurate or incomplete;
  - request that we erase your personal information in some circumstances, or object to our processing it as detailed at paragraph 8.5;
  - restrict how we use your personal information, in certain circumstances;
  - request that we provide you with copies of your personal information in a machine-readable format or transfer it across different services; and
  - where we have asked for your consent to process your data, to withdraw this consent.
- These rights are limited in some situations under Data Protection Law – for example, where we can demonstrate that we are under a legal obligation to process your data.
- If you wish to exercise any of these rights, please contact us using the details in paragraph 2
- Your right to object

You have a right to object to our processing of your personal data and ask us to stop doing so. If we are processing your personal data or direct marketing purposes (which includes profiling to the extent that it is related to such direct marketing) and you object to this, we will stop processing your personal data immediately.

If our processing of your personal data is in the public interest or pursuant to our legitimate interests and you object to this, we will stop processing your personal data unless we have compelling reasons which override your interests, or our use of your personal data is for the establishment, exercise or defence of legal claims.

We hope that we can satisfy any queries you may have about the way we process your data. However, if you have unresolved concerns you also have the right to complain to data protection authorities.

DATA RETENTION
- Your personal data will only be kept for as long as necessary for our purposes. Specific periods are set out in the table at the end of this notice.
DATA PROTECTION PRINCIPLES
- We process your personal data in accordance with the following principles:
  - we process your personal data lawfully, fairly and in a transparent way;
  - we collect your personal data for specified, explicit and legitimate purposes; any further processing we do is compatible with the original purposes for which for which we collected it;
  - we only process personal data which is adequate, relevant and limited to what is necessary to achieve the purpose for which it is processed;
  - we take reasonable steps to ensure that all personal data is accurate and kept up to date where necessary;
  - we do not store personal data in a form which identifies you for any longer than is necessary for the purposes of processing; and
  - we process personal data securely and in a way that protects against unauthorised or unlawful processing, accidental loss, destruction or damage.
- When we ask for your personal data we will tell you whether you are required by law or contract to provide it, and what will happen if you do not provide the data.
- Any request for consent to the processing of your personal data will be made directly to you and will include information about why we require the personal data and what will be done with it.
WHAT IS OUR LAWFUL BASIS FOR PROCESSING?
- We will only process personal data when we have a lawful basis for doing that processing. The table at the end of this notice sets out the lawful basis we rely on for each type of data we process.
- We will choose one of the lawful bases in the GDPR to justify how we use your personal data. These are:
  - Consent: You have given consent to the processing of your personal data for one or more specific purposes.
  - Contract: The processing is necessary for the performance of a contract with you or in order to take steps at your request before entering into a contract.
  - Legal obligation: We need to process your personal data to comply with a legal obligation.
  - Vital interests: The processing is necessary to protect the vital interests of you or another person.
  - Public interest: Processing is necessary for the performance of a task carried out in the public interest or in the exercise of some official authority.
  - Legitimate interests: Processing is necessary for the purposes of legitimate interests pursued by us or someone else, except where such interests are overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.

SPECIFICALLY FOR THE SUB-DOMAIN ACADEMY.ASTOTZ.COM

The below is also applicable to anyone registering for one or more courses on the sub-domain academy.astotz.com hosted by Thinkific Labs Inc. (“Thinkific”).

PRIVACY STATEMENT

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1. What information do we collect and what do we do with it?

When you enroll as a student or subscriber (“learner”) on our site or related courses, as part of the enrolling process, we collect the personal information you give us such as your name and email address.

Email marketing: we may send you emails about our site and related course(s), registration, course content, your course progress or other updates. We may also use your email to inform you about changes to the course, survey you about your usage, or collect your opinion.

2. How do you get my consent?

When you provide us with personal information to become a learner on our site, make a purchase, or participate in the course, you imply that you consent to our collecting it and using it for that specific reason only.

If we ask for your personal information for a secondary reason, like marketing, we will either ask you directly for your expressed consent, or provide you with an opportunity to say no.

How do I withdraw my consent?

If after you opt-in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at anytime, by contacting us at INSERT EMAIL or mailing us at: INSERT MAILING ADDRESS

3. Disclosure

We may disclose your personal information if we are required by law to do so or if you violate our Terms of Service [INSERT LINK to your Terms of Service].

4. Thinkific

Our course and site is hosted by Thinkific Labs Inc. (“Thinkific”). They provide us with the online course creation platform that allow us to sell our product/services to you.

Your data is stored through Thinkific’s data storage, databases and the general Thinkific application. They store your data on a secure server behind a firewall.

Payment:

If you make a purchase on our site, we use a third party payment processor such as Stripe or Paypal. Payments are encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction.

All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover.

PCI-DSS requirements help ensure the secure handling of credit card information by our site and related courses and its service providers.

For more insight, you may also want to read Thinkific’s Terms of Service here https://www.thinkific.com/resources/privacy-policy/ or Privacy Statement here https://www.thinkific.com/resources/terms-of-service/ .

5. Third Party Services

In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.

However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.

For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.

Certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us. If you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.

As an example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.

Once you leave our course website or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our website’s Terms of Service.

Links

When you click on links on our course site, they may direct you away from our site. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements.

6. Security

To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed.

If you provide us with your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with a AES-256 encryption. Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards.

We collect cookies or similar tracking technologies. This means information that our website’s server transfers to your computer. This information can be used to track your session on our website. Cookies may also be used to customize our website content for you as an individual. If you are using one of the common Internet web browsers, you can set up your browser to either let you know when you receive a cookie or to deny cookie access to your computer.

We use cookies to recognize your device and provide you with a personalized experience.
We also use cookies to attribute visits to our websites to third-party sources and to serve targeted ads from Google, Facebook, Instagram and other third-party vendors.
Our third-party advertisers use cookies to track your prior visits to our websites and elsewhere on the Internet in order to serve you targeted ads. For more information about targeted or behavioral advertising, please visit https://www.networkadvertising.org/understanding-online-advertising.
Opting out: You can opt out of targeted ads served via specific third-party vendors by visiting the Digital Advertising Alliance’s Opt-Out page.
We may also use automated tracking methods on our websites, in communications with you, and in our products and services, to measure performance and engagement.
Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.

Web Analysis Tools

We may use web analysis tools that are built into the BUSINESS NAME website to measure and collect anonymous session information.

7. Age of Consent

By using this site, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence.

8. Changes to this Privacy Policy

We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.

If our site or course is acquired or merged with another company, your information may be transferred to the new owners so that we may continue to sell products to you.

QUESTIONS AND CONTACT INFORMATION

If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information contact our Privacy Compliance Officer at info@astotz.com.