Privacy Policy

While we have not made any material changes to the way we process data about our users, we have updated this policy to make it shorter and easier to read, and to comply with the EU General Data Protection Regulation coming into force on May 25, 2018.

We at Majoritas Global Ltd. (hereby Majoritas) respect your privacy and want you to understand how we process (collect, use, secure, share and delete) your personal data. This Privacy Policy covers our data processing practices and describes your rights to access, correct, restrict or delete our use of your personal data.

Unless we link to a different policy or state otherwise, this Privacy Policy applies when you visit or use the Majoritas website, its affiliated platforms, mobile applications, APIs or related services (the “Services”).

By using the Services, you agree to be bound by the terms of this Privacy Policy. You shouldn’t use the Services if you don’t agree with this Privacy Policy or any other agreement that governs your use of the Services.

Table of Contents

What Data We Process
How We Process Your Personal Data
What We Use Your Data For
Whom We Share Your Data With
Security
Your Rights
Jurisdiction-Specific Rules
Updates & Contact Info

1. What Data We Process

We collect certain data from you directly, like information you enter yourself, data about your participation on our platform and data from third-party platforms you connect with Majoritas. We also collect some data automatically, like information about your device.

Other information we may ask users to provide (optional):

Location
Address
Zip code
Date of birth
Gender
Phone number
Marital status
Number of children
Education
Profession
Social media channels’ URLs
Which issues are considered the most important
IP address
Level of engagement inside the website
History of user’s activity on the website

1.1 Data You Provide to Us

We may collect different data from or about you depending on how you use the platform. Below are some examples to help you better understand the data we collect.

When you create an account and use the platform, including through a third-party platform, we collect any data you provide directly, including:

Profile Data	You can also choose to provide profile information like a photo, gender, location, address, zip code, date of birth, phone number, marital status, number of children, education, profession, social media channels’ URLs, which issues are considered the most important, IP address, level of engagement inside the website, history of user’s activity on the website. Your Profile Data will be publicly viewable by others.
Shared Content	Parts of the website let you interact with other users or share content publicly, including by posting comments, giving feedback or posting photos or other work you upload. Such shared content may be publicly viewable by others depending on where it is posted.
Actions Data	When you do specific actions on the website, we collect certain data including which actions you’ve started and completed, your recommendations to other people, how many people/followers you’ve gained doing these actions.
Data About Your Accounts on Other Services	We may obtain certain information through your social media or other online accounts if they are connected to your website account. If you log in to website via Facebook or another third-party platform or service, we ask for your permission to access certain information about that other account. For example, depending on the platform or service, we may collect your name, profile picture, account ID number, login email address, location, physical location of your access devices, gender, age range. Those platforms and services make information available to us through their APIs. The information we receive depends on what information you (via your privacy settings) or the platform or service decide to give us. If you access or use our website through a third-party platform or service, or click on any third-party links, the collection, use, and sharing of your data will also be subject to the privacy policies and other agreements of that third party.
Communications and Support	If you contact us for support or to report a problem or concern (regardless of whether you have created an account), we collect and store your contact information, messages, and other data about you, such as your name, email address, location, operating system, IP address, and any other data you provide or that we collect through automated means (which we cover below). We use this data to respond to you and investigate your question or concern, in accordance with this Privacy Policy.

The data listed above is stored by us and associated with your account.

1.2 Data We Collect through Automated Means

When you access the website (including browsing courses), we collect certain data by automated means, including:

System Data	Technical data about your computer or device, like your IP address, device type, operating system type and version, unique device identifiers, browser, browser language, domain and other systems data, and platform types (“System Data”).
Usage Data	Usage statistics about your interactions with the website, including pages accessed, time spent on pages, actions done, email actions as click data, date and time, and other information regarding your use of the Services (“Usage Data”).
Approximate Geographic Data	An approximate geographic location, including information such as country, city, and geographic coordinates, based on your IP address.

The data listed above is collected through the use of server log files and tracking technologies, as detailed in the “Cookies and Data Collection Tools” section below. It is stored by us and associated with your account.

2. How We Process Your Personal Data

We use tools like cookies, web beacons, analytics services, and advertising providers to gather the data listed above. Some of these tools offer you the ability to opt out of data collection.

2.1 Cookies and Data Collection Tools

Majoritas and service providers acting on our behalf (such as, but not limited to, Google Analytics and third-party advertisers) use server log files and automated data collection tools like cookies, tags, scripts, customized links, device or browser fingerprints, and web beacons (together, “Data Collection Tools”) when you access and use the Services. These Data Collection Tools automatically track and collect certain System Data and Usage Data (as detailed in Section 1) when you use the website. In some cases, we link data through those Data Collection Tools with other data that we collect as described in Majoritas’ Privacy Policy.

We use cookies (small files that websites send to your device to uniquely identify your browser or device or to store data in your browser) for purposes related to analyzing your use of the website, personalizing your experience, making it easier to log in to the website, and recognizing you when you return. We use web beacons (small objects that allow us to measure the actions of visitors and users using the website) for purposes related to identifying whether a page was visited, identifying whether an email was opened, and advertising more efficiently by excluding current users from certain promotional messages or identifying the source of a new mobile app download. Some of the third-party partners who provide certain features on our site may also use Local Storage Objects (also known as flash cookies or LSOs) to collect and store data.

For more information on our use of cookies, please read our Cookie Policy.

2.2 Analytics

We use third-party browser and mobile analytics services such as Google Analytics on our website. These services use Data Collection Tools to help us analyze your use of the website, including information like the third-party website you arrive from, how often you visit, events within the website, usage and performance data, and where the application was downloaded from. We use this data to improve the website, better understand how the website performs on different devices, and provide information that may be of interest to you.

2.3 Online Advertising

We use third-party advertising services like Facebook Ads, Google AdWords, and other ad networks and servers to deliver advertising about our website on other websites and applications you use. The ads may be based on information we collected about you, such as your Usage Data and System Data (as detailed in Section 1), and data that these ad service providers know about you based on their tracking systems. The ads may be based on your recent activity or activity over time and across other websites and services and may be tailored to your interests.

Depending on the types of advertising services we use, they may place cookies or other tracking technologies on your computer, phone, or other device to collect data about your use of our website and may access those tracking technologies in order to serve these tailored advertisements to you. To help deliver tailored advertising, we may provide these service providers with a hashed, anonymized version of your email address (in a non-human-readable form) and content that you share publicly on the Services.

When using mobile applications, you may also receive tailored in-app advertising. Apple iOS, Android OS, and Microsoft Windows each provides its own instructions on how to control in-app tailored advertising. For other devices and operating systems, you should review your privacy settings or contact your platform operator.

3. What We Use Your Data For

We use your data for purposes such as providing information on the website, communicating with you, troubleshooting issues, securing ourselves against fraud and abuse, improving and updating our website, analyzing how visitors use our website, serving personalized advertising, and as required by law or necessary for safety and integrity.

We use the data we collect through your use of the platform to:

Provide and manage the website, including to display customized content and facilitate communication with other users;
Communicate with you about your account by:
- Responding to your questions and concerns;
- Sending you administrative messages and information, including messages administrators, notifications about changes to our websites, and updates to our policies;
- Sending you information and in-app messages about new actions, rewards programs, new features, promotions, newsletters and other information;
- Sending push notifications to your wireless device to provide updates and other relevant messages.
Manage your account preferences;
Facilitate the Services’ technical functioning, including troubleshooting and resolving issues, securing the Services, and preventing fraud and abuse;
Request feedback from users;
Learn more about you by linking your data with additional data through third-party data providers or analyzing the data with the help of analytics service providers;
Improve our website and develop new features;
Analyze trends and traffic, and track usage data;
Advertise the website on third-party websites and applications;
As required or permitted by law;
As we, at our sole discretion, otherwise determine to be necessary to ensure the safety or integrity of our users, employees, third parties, the public, or our website.

4. Whom We Share Your Data With

We share certain data about you with companies performing services for us, our business partners, analytics and data enrichment providers, your social media providers, companies helping us run surveys and advertising companies who help us promote our website. We may also share your data as needed for security, legal compliance, or as part of a corporate restructuring. Lastly, we can share data in other ways if it is aggregated or de-identified or if we get your consent.

We may share your data with third parties under the following circumstances or as otherwise described in this Privacy Policy:

With Administrator: We share data that we have about you with website administrators, so they can improve the website for you and other community members. This data may include your profile information and your usage data. If we collect additional data about you (like age or gender), we may share that too. We also enable our administrators to implement Google Analytics on website pages to track sources of traffic to website pages and optimize them;
With Other Website Community Members & Visitors: Depending on your settings, your shared content and profile data may be publicly viewable, including to other community members or visitors. If you comment on a webpage, your information (including your name) will be publicly viewable by others;
With Service Providers, Contractors, and Agents: We share your data with third-party companies who perform services on our behalf, like data analysis, marketing and advertising services (including retargeted advertising), email and hosting services, and customer services and support. These service providers may access your personal data and are required to use it solely as we direct, to provide our requested service.
With Business Partners: We have agreements with other websites and platforms to advertise our website and drive traffic to it. Depending on your location, we may share your data with these partners;
With Analytics and Data Enrichment Services: As part of our use of third-party analytics tools such as Google Analytics and data enrichment services we share certain contact information, Account Data, System Data, Usage Data (as detailed in Section 1), or de-identified data as needed. De-identified data means data from which we’ve removed things information such as your name and email address and replaced it with a token ID. This process allows these providers to provide analytics services or match your data with publicly-available database information (including contact and social information from other sources). We do this to communicate with you in a more effective and customized manner;
To Power Social Media Features: The social media features in the Services (like the Facebook Like button) may allow the third-party social media provider to collect things like your IP address and which page of the Services you’re visiting, and to set a cookie to enable the feature. Your interactions with these features are governed by the third-party company’s privacy policy;
To Administer Contests and Surveys: We may share your data as necessary to administer, market, or sponsor contests and surveys you choose to participate in, as required by applicable law (such as providing a winners list or making required filings), or in accordance with the rules of the contest or survey;
For Advertising: If we decide to offer advertising in the future, we may use and share certain System Data and Usage Data with third-party advertisers and networks to show general demographic and preference information among our users. We may also allow advertisers to collect System Data through Data Collection Tools (as detailed in Section 2.1), and to use this data to offer you targeted ad delivery to personalize your user experience (through behavioral advertising) and undertake web analytics. Advertisers may also share with us the data they collect about you. To learn more or opt out from participating ad networks’ behavioral advertising, see Section 6.1 (Your Choices About the Use of Your Data) below. Note that if you opt out, you’ll continue to be served generic ads;
For Security and Legal Compliance: We may disclose your data to third parties if we (at our sole discretion) have a good faith belief that the disclosure is:

- Permitted or required by law;
- Requested as part of a judicial, governmental, or legal inquiry, order, or proceeding;
- Reasonably necessary as part of a valid subpoena, warrant, or other legally-valid request;
- Reasonably necessary to enforce our Terms of Use, Privacy Policy, and other legal agreements;
- Required to detect, prevent, or address fraud, abuse, misuse, potential violations of law (or rule or regulation), or security or technical issues;
- Reasonably necessary at our discretion to protect against imminent harm to the rights, property, or safety of the website, our users, employees, members of the public, or Majoritas;
- We may also disclose data about you to our auditors and legal advisors in order to assess our disclosure obligations and rights under this Privacy Policy.

During a Change in Control: If Majoritas undergoes a business transaction like a merger, acquisition, corporate divestiture, or dissolution (including bankruptcy), or a sale of all or some of its assets, we may share, disclose, or transfer all of your data to the successor organization during such transition or in contemplation of a transition (including during due diligence);
After Aggregation/De-identification: we can disclose or use aggregate or de-identified data for any purpose.

5. Security

We use appropriate security based on the type and sensitivity of data being stored. As with any internet-enabled system, there is always a risk of unauthorized access, so it’s important to protect your password and to contact us if you suspect any unauthorized access to your account.

Majoritas takes appropriate security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal data that we collect and store. These measures vary based on the type and sensitivity of the data. Unfortunately, however, no system can be 100% secured, so we cannot guarantee that communications between you and us or any information provided to us in connection with the data we collect through the website will be free from unauthorized access by third parties. Your password is an important part of our security system, and it is your responsibility to protect it. You should not share your password with any third party, and if you believe your password or account has been compromised, you should change it immediately and contact us at [email protected] with any concerns.

6. Your Rights

You have certain rights regarding our use of your data, including the ability to opt out of promotional emails, cookies, and collection of your data by certain analytics providers. You can update or terminate your account from within our platform and you may also contact us for individual rights requests about your personal data. Parents who believe we’ve unintentionally collected personal data about their underage child should contact us so that we delete that information.

6.1 Your Choices About the Use of Your Data

You can choose not to provide certain data to us, but you may not be able to use certain features of the Services.

To stop receiving promotional communications from us, you can opt out by using the unsubscribe mechanism in the promotional communication you receive or by changing the email preferences in the account. Note that regardless of your email preference settings, we will send you transactional and relationship messages regarding the website, including administrative confirmations, important updates about the website, and notices about our policies.
The browser or device you use may allow you to control cookies and other types of local data storage. Your wireless device may also allow you to control whether location or other data is collected and shared. You can manage Adobe’s LSOs through their Website Storage Settings panel.
To get information and control cookies used for tailored advertising from participating companies, please visit the consumer opt-out pages for the Network Advertising Initiative and Digital Advertising Alliance, or if you’re located in the European Union, visit the Your Online Choices site. To opt out of Google’s display advertising or customize Google Display Network ads, visit the Google Ads Settings page. To opt out of Taboola’s targeted ads, see the Opt-out Link in their Cookie Policy.
To opt out of Google Analytics, Hotjar, Mixpanel, ZoomInfo, or Clearbit, please visit Google Analytics Opt-out Browser Add-on, Hotjar Opt-Out Cookie, Mixpanel Opt-Out Cookie, ZoomInfo’s policy, and Clearbit data claiming mechanism.

If you have any questions about your data, our use of it, or your rights, please contact our Data Protection Officer at [email protected].

6.2 Accessing, Updating, and Deleting Your Personal Data

You can access and update your personal data that we collect and maintain as follows:

To update data you provide directly, log in to your account and update your account at any time;
To terminate your account:

- If you would like to delete your account, please email us at [email protected].
- Please note: even after your account is terminated, some or all of your data may still be visible to others, including without limitation to, any data that has been (a) copied, stored, or disseminated by other users (including in course comment); (b) shared or disseminated by you or others (including in your shared content); or (c) posted to a third-party platform. Even after your account is terminated, we reserve the right to retain your data for as long as we have a legitimate purpose to do so (and in accordance with applicable law), including to assist with legal obligations, resolve disputes, and enforce our agreements. We may retain and disclose such data pursuant to this Privacy Policy after your account has been terminated.

To request the right to access, object to processing, correct, port or delete (the right to be forgotten) your personal data, please email our Data Protection Officer or write to us at [email protected]. Please allow up to 30 days for a response. For your protection, we may require that the request be sent through the email address associated with your account, and we may need to verify your identity before implementing your request;
Please note that we may access, preserve, and share your information in response to a legal request (like a search warrant, court order, or subpoena) if we have a good faith belief that the law requires us to do so. This may include responding to legal requests from jurisdictions outside of the European Economic Area where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards. We may also access, preserve and share information when we have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you and others, including as part of investigations; or to prevent death or imminent bodily harm. For example, we may provide information to third-party partners about the reliability of your account to prevent fraud and abuse on and of our platform. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm. We also may retain information from accounts disabled for violations of our terms for at least a year to prevent repeat abuse or other violations of our terms.

6.3 Our Policy Concerning Children

We recognize the privacy interests of children and encourage parents and guardians to take an active role in their children’s online activities and interests. People under 18 in the European Economic Area should not use the website. If we learn that we’ve collected personal data from a minor (under 18 years of age), we will take reasonable steps to delete it.

Parents or other users, who believe that we may have collected personal data from a child under this age can submit a request that it be removed to our Data Protection Officer at [email protected].

7. Jurisdiction-Specific Rules

7.1 Users outside the EU

If you are a non-EU resident, you have the right to request certain details about what personal information we share with third parties for those third parties’ direct marketing purposes. To submit your request, please send an email to [email protected] with the phrase and include your mailing address, state of residence, and email address.

Since the internet industry is still working on Do Not Track standards, solutions, and implementations, we do not currently recognize or respond to browser-initiated Do Not Track signals.

7.2 Users in the EU

Majoritas is headquartered in 2003, 20/F, Tower 5, China, Hong Kong City, 33 Canton Road, Tsim Sha Tsui, Kawloon, and in order for our platform to function, we must transfer your data to servers located in your country of residence and process it there. By visiting or using our website, you consent to the storage of your data to servers located in your country of residence. If you are using the website from the EU, you consent to the transfer, storage, and processing of your personal data in and to the EU or other countries. This refers specifically to personal data collected on servers located in your country of residence and the European Economic Area (“EEA”).

That data is also processed outside of your country of residence and the EEA by our group companies, or our service providers to provide support services as described at Paragraph 4. We have entered into data processing agreements with our service providers that restrict and regulate their processing of your data on our behalf. By submitting your data or using our website, you consent to this transfer, storage, and processing by Majoritas and its processors.

8. Updates & Contact Info

When we make a material change to this policy, we’ll notify users via email, in-product notice, or another mechanism required by law. Changes become effective the day they’re posted. However, please be advised that if we fail to send you any information on our Privacy Policy updates, it is understood that your continuous use of our services and website is your implicit agreement to our revised/updated Privacy Policy whenever you visit our website. Please contact us via email or postal mail with any questions, concerns, or disputes.

8.1 Modifications to This Privacy Policy

From time to time, we may update this Privacy Policy. If we make any material change to it, we will notify you via email, through a notification posted on the website, or as required by applicable law. We may also, at our sole discretion, include a summary of the key changes. Unless stated otherwise, modifications will become effective on the day they are posted.

As permitted by applicable law, if you continue to use the website after the effective date of any change, then your access and/or use will be deemed an acceptance of (and agreement to follow and be bound by) the revised Privacy Policy. The revised Privacy Policy supersedes all previous Privacy Policies.

8.2 Interpretation

Any capitalized terms not defined in this policy are defined as specified in Majoritas Terms of Use. Any version of this Privacy Policy in a language other than English is provided for convenience. If there is any conflict with a non-English version, you agree that the English language version will supersede.

8.3 Questions

If you have any questions, concerns, or disputes regarding our Privacy Policy, please feel free to contact our team (including our designated Data Protection Manager) at [email protected]. You can also send postal mail to us at 2003, 20/F, Tower 5, China, Hong Kong City, 33 Canton Road, Tsim Sha Tsui, Kawloon.