Definitions

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

General

Omnicourse obtains personal information concerning you from certain sources to provide the Services and to manage the Omnicourse Platform. “You” may be a Visitor, User, or Creator regarding our Services.

a. Omnicourse Platform VisitorsIf you access or visit our Platform, we may collect your personal information. For example, we collect Personal Data that you shared with us via membership form, or when you contact us by e-mail.

b. Omnicourse UsersWhen you visit our Platform, you may create different membership accounts depending on the process you will carry out. Here are the User titles specified in our Platform: Individual Member: It shall mean the natural person who carries out membership transactions on the Omnicourse Platform on his/her own behalf, and accordingly who is entitled to access to library of all Audio Courses, Learnbites, and Services within the scope of the paid subscription. Creator: It shall mean the natural person who carries out membership transactions on the Omnicourse Platform on his/her own behalf, provides Audio Courses and Learnbites to Users through pre-recorded audio content.

c. Payment Processing ServicesOmnicourse may use third-party services to provide payment processing and associated services. Third-party payment systems may request various payment information from Users (credit card information, name-surname, region, etc.).

Omnicourse is solely the processor of Personal Data collected through its Services and is not responsible for the collection and processing of Personal Data with regard to third-party payment systems and other payment services.

Third-party payment systems are bound by their own use and privacy policies, and Omnicourse cannot be held responsible for behaviors of the third-party payment systems that violate any right arising from personal data protection legislation.

4. Coverage and Usage of Omnicourse Services

Omnicourse Platform is a subscription-based capsule-sized audio course platform that enables Users to build a daily learning habit with world-class Audio Courses and insightful Learnbites.

Unless otherwise stated by Omnicourse, subscription packages or Services offered within the scope of the Omnicourse Platform are provided in an electronic environment and no physical delivery will be made to the Users.

The Services is intended solely for personal and non-commercial use by you. Any use of the Service other than for personal and non-commercial purposes is strictly prohibited.

Types of Data Collected

a. Personal Data that We Collect from YouWhile using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:

• First name and last name
• Email address
• Occupational information (occupation, expertise etc.)
• Social media profile URL (Twitter, LinkedIn)
• Profile picture
• Usage Data

When you respond to Omnicourse’s e-mails we collect your e-mail address, name, and any other information you choose to include in the body of your e-mail or response. If you contact us by phone, we will collect the phone number you use to call Omnicourse.

You may also opt-in to submitting information through other methods, including:

• By participating in an offer, program, or promotion,
• Through our social media accounts or online forums,
• In connection with a real or potential business relationship with us,
• By giving us your business card or contact information.

b. Information that We Collect Automatically on Our Platform and ServicesOur Platform uses cookies and other technologies to function effectively. These technologies record information about your usage of our Platform, including:

• Browser and Device Data, such as IP address, device type, internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons, brand, model, technical specification and operating system information of the device used, and the language version of the Platform you are visiting;
• Usage Data, such as time spent on the Platform, pages visited, links clicked, language preferences, Platform usage time, communication preferences, payment amount, payment channels, approaches to in-platform notifications/offers/campaigns, habits, favorites, likes, behaviors, preferences, search activities, segments, cookie records, cookie and ad identifier and Device ID, and the pages that led or referred you to our Platform.

We also may collect information about your online activities on the Platform and connected Devices over time and across third-party sites, devices, apps, and other online features and services. We use web log analysis software (Google Analytics etc.) on our Platform to help us analyze your use of our Platform and diagnose technical issues.

While using our Service, in order to provide features of our Platform, we may collect, with your prior permission, pictures and other information from your Device's camera and photo library. We use this information to provide features of our Service, to improve and customize our Service. The information may be uploaded to the Company's servers and/or a Service Provider's server or it be simply stored on your device. You can enable or disable access to this information at any time, through your Device settings.

To learn more about the cookies that may be served through our Platform and how you can control our use of cookies and third-party analytics, please see our Cookie Policy section.

Use of Personal Data

a. Our ServicesWe rely upon several legal grounds to ensure that our use of your Personal Data is compliant with the applicable law. We use Personal Data to facilitate the business relationships we have with our Users, to comply with legal obligations, and to pursue our legitimate business interests.

Contractual and pre-contractual business relationships. We use Personal Data to enter business relationships with prospective Users and to perform the contractual obligations under the contacts that we have with Users. Activities that we conduct in this context include: Creation and management of Accounts, including the evaluation of applications to commence or expand the use of our Services; Accounting, auditing, and billing activities; and Processing of payments, communications regarding such payments, and related customer services.

Legal and regulatory compliance. We use Personal Data to verify the identity of our Users in order to comply with laws. These obligations are imposed on us by the operation of law, industry standards, and by our financial partners, and may require us to report our compliance to third parties and to submit to third-party verification audits. Legitimate business interests. We rely on our legitimate business interests to process certain Personal Data concerning you. The following list sets out the business purposes that we have identified as legitimate. In determining the content of this list, we balanced our interests against the legitimate interests and rights of the individuals whose Personal Data we process. Mitigating financial loss, claims, liabilities, or other harm to Users and Omnicourse; Responding to inquiries, sending service notices, and providing customer support; Promoting, analyzing, modifying, and improving our products, systems, and tools, and developing new Services; Managing, operating, and improving the performance of our Platform and Services by understanding their effectiveness and optimizing our digital assets; Analyzing and advertising our Services; Conducting aggregate analysis and developing business intelligence that enables us to operate, protect, make informed decisions, and report on the performance of our business; Sharing Personal Data with Third-Party Service Providers that provide services on our behalf and business partners who help us operate and improve our business; Ensuring network and information security throughout the Platform and our Services.

Payment transactions and related services. We use third-party payment services for payment transactions. The data you provide to complete the payment process is collected and processed by the third-party payment processing service providers. We recommend that you review these third-party payment services’ Privacy Policy and Terms of Use to learn how they handle your Personal Data.

If we need to use your Personal Data in other ways, we will make a specific notice at the time of collection and we will get your consent if the applicable laws require.b. Marketing and Events-related CommunicationsWe may send you e-mail marketing communications about Omnicourse and its Services, invite you to participate in our events or surveys, or otherwise communicate with you for marketing purposes, provided that we do so in accordance with the consent requirements that are imposed by applicable law. When we collect your business, contact details through our participation at trade shows or other events, we may use the information to follow-up with you regarding an event, send you information that you have requested on our products and Services, and with your permission, include you on our marketing information campaigns.c. Interest-based AdvertisingWhen you visit our Platform, both certain third parties and we collect information about your online activities over time and across different websites to provide you with advertising products and services tailored to your individual interests (this type of advertising is called “interest-based advertising”). These third parties may place or recognize a unique cookie or other technology on your browser. Where required by applicable law, we will obtain your consent prior to processing your information for interest-based advertising.

Since we also participate in advertising networks, you may see our ads on other websites or mobile apps. Ad networks allow us to target our messaging to users based on a range of factors, including demographic data, users’ inferred interests, and browsing context (for example, the time and date of your visit to our Platform, the pages that you viewed, and the links that you clicked). This technology also helps us track the effectiveness of our marketing efforts and understand if you have seen one of our advertisements.

We work with advertising networks (Google AdWords, Facebook, etc.). To learn how to opt-out from behavioral advertising delivered by Network Advertising Initiative member companies, please visit the Network Advertising Initiative and Digital Advertising Alliance. If you opt-out from interest-based advertising, you may see advertising that is not relevant to you.

How We Share Personnal Data

Omnicourse may share your Personal Data to (i) satisfy any applicable law, regulation, legal process, or governmental request; (ii) enforce this Policy and our Terms and Conditions, including investigation of potential violations hereof; (iii) detect, prevent, or otherwise address fraud, security, or technical issues; (iv) respond to your requests; or (v) protect our rights, property or safety, our Users and the public.

We share Personal Data with a limited number of our Service Providers. We have Service Providers that provide services on our behalf, such as website hosting, data analysis, information technology, and related infrastructure, customer service, e-mail delivery, and auditing services. These service providers may need to access Personal Data to perform their services. We authorize such service providers to use or disclose Personal Data only as necessary to perform services on our behalf or comply with legal requirements. We require such service providers to contractually commit to protect the security and confidentiality of Personal Data they process on our behalf. Our service providers are predominantly located in the European Union and the United States of America.

We may disclose information in the aggregate form to third parties relating to user behavior in connection with the actual or prospective business relationship with those third parties, such as advertisers and content distributors.

We will encourage our service partners to adopt and post transparent privacy policies. However, the use of your personal information by our service partners is governed by their privacy policies and is not subject to our control. You acknowledge that we are not responsible for the violations caused by our service partners.

We share Personal Data with third-party business partners when this is necessary to provide our Services to our Users. We share Personal Data with Users as necessary to maintain a User account and provide the Services. The use of Personal Data by an authorized third party is subject to the third party’s privacy policy.

In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share Personal Data with third parties for the purpose of facilitating and completing the transaction.

We share Personal Data as we believe necessary: (i) to comply with applicable law, or payment method rules; (ii) to enforce our contractual rights; (iii) to protect the rights, privacy, safety, and property of Omnicourse, you or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.

GDPR Privacy

Your Rights and Choices Under the GDPROmnicourse undertakes to respect the confidentiality of your Personal Data and to guarantee you can exercise your rights. You have the right under this Privacy Policy, and by law if you are within the EU, to:

Right of Access: You have the right to obtain confirmation from us as to whether or not Personal Data concerning you are processed, and, where that is the case, you have the right to request and get access to such Personal Data. Right to Rectification: You have the right to request rectification by us of inaccurate Personal Data and you have the right to provide additional Personal Data to complete any incomplete Personal Data.

Right to Erasure (“Right to be Forgotten”): In certain cases, you have the right to request from us the erasure of your Personal Data. Right to Restriction of Processing: You have the right to request from us restriction of processing, for a certain period and/or for certain situations.

Right to Data Portability: You have the right to receive your Personal Data from us in a structured format and you have the right to (let) transmit such Personal Data to another controller.

Right to Object: In certain cases, you have the right to object to the processing of your Personal Data, including with regards to profiling. You have the right to object to the further processing of your Personal Data in so far as such data has been collected for direct marketing purposes.

Right to be Not Subject to Automated Individual Decision-Making: You have the right to not be subject to a decision based solely on automated processing.

Right to Filing Complaint: You have the right to file complaints with the applicable data protection authority on our processing of your Personal Data.

Right to Compensation of Damages: In case we breach applicable legislation on the processing of your Personal Data, you have the right to claim damages from us for any damages such breach may cause to you.

Exercising of Your GDPR Data Protection Rights

You may exercise your rights of access, rectification, cancellation and opposition by simply contacting us. Please note that we may ask you to verify your identity before responding to such requests. If You make a request, we will try our best to respond to you as soon as possible.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.

CCPA Privacy

Your Rights and Choices Under the CCPAUnder this Privacy Policy, and by law if you are a resident of California, you have the following rights: Right to notice: You must be properly notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used. The right to access / the right to request: The CCPA permits you to request and obtain from the Company information regarding the disclosure of your Personal Data that has been collected in the past 12 months by the Company or its subsidiaries to a third-party for the third party's direct marketing purposes. The right to say no to the sale of Personal Data: You have the right to ask the Company not to sell your Personal Data to third parties. You can submit such a request by visiting our Platform. The right to know about Your Personal Data: You have the right to request and obtain from the Company information regarding the disclosure of the following: The categories of Personal Data collected The sources from which the Personal Data was collected The business or commercial purpose for collecting or selling the Personal Data Categories of third parties with whom We share Personal Data The specific pieces of Personal Data we collected about You The right to delete Personal Data: You also have the right to request the deletion of your Personal Data that have been collected in the past 12 months. The right not to be discriminated against: You have the right not to be discriminated against for exercising any of your Consumer's rights, including by: Denying goods or services to you Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties Providing a different level or quality of goods or services to you Suggesting that yyou will receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising Your CCPA Data Protection Rights

In order to exercise any of your rights under the CCPA, and if you are a California resident, You can email us or contact us via Omnicourse Platform.

The Company will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Do Not Sell My Personal Information

We do not sell personal information. However, the Service Providers we partner with (for example, our advertising partners) may use technology on the Service that "sells" personal information as defined by the CCPA. If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.

Website

You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service: From Our "Cookie Consent" notice banner Or from Our "CCPA Opt-out" notice banner Or from Our "Do Not Sell My Personal Information" notice banner The opt out will place a cookie on your computer that is unique to the browser you use to opt out. If you change browsers or delete the cookies saved by your browser, you will need to opt out again. Please note that any opt out is specific to the browser you use. You may need to opt out on every browser that you use.

Mobile Devices

Your mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests: "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices "Limit Ad Tracking" on iOS devices You can also stop the collection of location information from your mobile device by changing the preferences on your mobile device.

"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some third-party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services, or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if you are a California resident, you can contactuUs using the contact information provided to you, and include the email address associated with your account.

Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Security and Retention

We are making reasonable efforts to provide you with an appropriate level of security at the risk associated with the processing of your Personal Data. We take organizational, technical, and administrative measures designed to protect your Personal Data against unauthorized access, destruction, loss, alteration, or abuse. Your Personal Data may only be accessed by a limited number of personnel who need access to such information in order to perform their duties. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have a reason to believe that your interaction with us is no longer secure (for example, if you think your account is compromised), please contact us immediately.

If you are a User, we retain your Personal Data as long as we are providing the Services to you. We retain Personal Data after we cease providing Services to you, even if you close your Account, to the extent necessary to comply with our legal and regulatory obligations. We also retain Personal Data to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data due to our contractual commitments to our financial and business partners, and where data retention is mandated by the payment methods that we support. Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.

Cookie Policy

Cookies are small text files stored in a computer’s web browser memory. They help website providers with things like understanding how people use a website, remembering a user’s login details, and storing website preferences. This article explains how we use cookies and other similar technologies to help us ensure that our Services function properly, prevents fraud and other harm, and analyze and improve the Services in accordance with our Policy.a. How We Use CookiesCookies play an important role in helping us provide personal, effective, and safe Services. We use cookies on our Website. We change the cookies periodically as we improve or add to our Services, but we generally use cookies for the following purposes: To Operate Our Services: Some cookies are essential to the operation of our Website and Services. We use those cookies in several different ways, including: Authentication Performing payment transactions Site Features and Services Performing location submissions

To Analyze and Improve Our Services: Cookies help us understand how to make our Platform and Services work better for you. Cookies tell us how people reach our Platform, and they give us insights into improvements or enhancements we need to make to our Platform and Services. For Better Advertising: Cookies can help us provide more effective advertising on our Platform. For example, we might use a cookie to help to prevent you from seeing the same advertisement multiple times or to measure how many times an advertisement is viewed or clicked on.b. How We Use Other TechnologiesThird Party Analytics: We use Google Analytics which uses cookies and similar technologies, to collect and analyze information about the use of the Services and report on activities and trends. This service may also collect information regarding the use of other sites, apps, and online resources. You can learn about their practices on their website. Please refer to the table below for more on how we use third-party analytics.d. How to Manage CookiesYour web browser may allow you to change your cookie preferences, including to delete and disable cookies. Please consult the help section of your web browser to understand your options, but please note that if you choose to disable the cookies, some features of our Platform or Services may not operate as intended.

International Data Transfers

We are a global business. Personal Data may be stored and processed in any country where we have operations or where we engage service providers. We may transfer Personal Data that we maintain about you to recipients in countries other than the country in which the Personal Data was originally collected, including to the United States. Those countries may have data protection rules that are different from those of your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your Personal Data remains protected to the standards described in this Policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your Personal Data.

Use by Minors

The Services are not directed to individuals under the age of eighteen (18), and they shall not provide Personal Data through the Services. If you have reason to believe that anyone under the age of 18 has provided us with any personal information, please contact us.

Updates to This Policy and Notifications

We may change this Policy from time to time to reflect new services, changes in our Personal Data practices, or relevant laws. The “Last Updated” legend at the top of this Policy indicates when this Policy was last revised. Any changes are effective when we post the revised Policy on the Platform. We may provide you with disclosures and alerts regarding the Policy or Personal Data collected by posting them on our Platform and, if you are a User, by contacting you through Omnicourse Platform, e-mail address.

Links to Other Websites

The Services may provide the ability to connect to other sites. These sites may operate independently from us and may have their own privacy notices or policies, which we strongly suggest you to review. If any linked website is not owned or controlled by us, we are not responsible for its content, any use of the website, or the privacy practices of the operator of the website.

Jurisdiction

Omnicourse focuses on multinational compliance regulations including but not limited to United States Privacy Law and, the General Data Protection Regulation (“GDPR”) brought by the European Union to make sure privacy is a “go-to” rather than a thing to be worried. You have the right to request further information on our personal data processing activities based on your country's laws.