Last Updated: 01 February 2022

PRIVACY POLICY

CREATIVE BUTTERFLY LLC and KOOKADEE Inc. located at 490 Post Street, Ste.526 San Francisco, CA 94102 USA, an owner of the Le Sallay Academy brand and its affiliated companies (hereinafter referred to as "Le Sallay Academy" or “we“) are committed to protecting and respecting your privacy and is the data controller for your Personal Information under this Privacy Policy.

This Privacy Policy outlines how we collect, use, process, disclose, transfer, and store your Personal Information when you use our website, and/or data collection tools (collectively the “Services”). Please read this Privacy Policy carefully to understand how we treat your Personal Information and Data that we may obtain in the course of providing our Services.

1) Definition

“Personal Information” refers to any information relating to an identified or identifiable natural person(“Personal Data Subject”). An identifiable natural person is one who can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location information, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

2) What and How We Collect Your Personal Information

The Personal Information can be collected directly from the Personal Data Subject or from a Third Party with the consent of the Personal Data Subject or where permitted by law.

Le Sallay Academy is responsible for the processing and treatment of Personal Information. The Personal Information collected by Le Sallay Academy can include but is not limited to:

• full name, address, and contact details
• job title and employer details
• date of birth
• gender
• nationality
• identification

2.1) Information You Directly Provide to Us
Certain Personal Information concerning you is collected directly from you by Le Sallay Academy.
We might collect the Personal Information in the following circumstances:

• when you fill in a contract for one of our Services
• when you sign up on our website for our newsletter
• when you sign up on our website to request information and place an order of our Services
• when you submit a request for a quote or send an inquiry via the contact forms on our website
• when you reply to an email from Le Sallay Academy that you have previously consented to be sent to you
• if you contact us or send us a message through social media channels

The information above may be necessary for the adequate performance of the contract or purchase order between you and Le Sallay Academy and to allow us to comply with our legal obligations.

2.2) Information We Collect from Third Parties
To enable us to provide better Services to you, where permitted by applicable laws, we may collect your Personal Information indirectly from a Third Party.
We will put efforts to ensure the legitimacy of the source of your Personal Information. However, please note that we do not control, supervise or respond to how the Third Party processes your Personal Information. Any request regarding the disclosure of your Personal Information to us should be directed to such Third Party.

2.3) Information We Automatically Collect from You with Cookies and Similar Technologies
A Cookie is a plain text file that is stored on computers or mobile devices by web servers. The contents of Cookies can only be retrieved or read by its creating server. Every Cookie is unique to your web browser or mobile application. A Cookie usually includes an identifier, site name, and some numbers and characters. Using Cookies, a website can store data of user preferences, etc.
To ensure that our website is working normally and to personalize and customize your experience, we will use Cookies or similar tracking technologies, such as web beacons, pixels, and mobile identifiers to analyze trends, operate our website, track users’ movements around the websites, and to gather demographic information about our user base as a whole. We will not use Cookies for any purpose other than those stated in this Privacy Policy.
You may manage or delete Cookies based on your preferences. You can clear all Cookies on your computer and most web browsers have the Do Not Track function. If Do Not Track is enabled on your browser, all of our websites will respect your choice.
Le Sallay Academy does use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics does make use of cookies in order to facilitate analysis of how users use the Site and to track Site traffic. This data does not identify individual users and Le Sallay Academy is not able to use this data to individually identify any user of the site. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that should you refuse the use of cookies, you may not be able to use certain features otherwise available on the Site.

3) How We Use Your Personal Information

We collect your Personal Information so that we can:

• perform our Services
• improve our Services
• keep you updated about our Services
• contact you with other relevant Services we think you might be interested in

3.1) Use Upon Your Consent
We may process your Personal Information for the purposes as follows with your consent.

• Provide and improve our Services: The Personal Information we collect will be used to provide you with our Services, process your orders or fulfill the contract between you and Le Sallay Academy. In particular, we will not use your Genetic Data for any purpose other than to provide our Services without your prior consent.
• Advertising and marketing: The Personal Information we collect will be used to personalize and improve our advertising, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences. You can opt out of receiving marketing messages from us easily by following the unsubscribe instructions included in our marketing messages. After you choose to opt-out, we will stop processing and delete your relevant Personal Information promptly.

We will acquire your consent in advance when the information is to be used for a purpose that is not specified in this Privacy Policy. We will acquire your consent in advance when the information collected for a specific purpose is to be used for other purposes.

3.2) Use Without Your Consent
In accordance with applicable laws, Le Sallay Academy may process your Personal Information for one of the following purposes without your consent:

• To perform its contractual obligations;
• To protect the vital interests of the Personal Data Subject or another natural person if the Personal Data Subject is physically or legally incapable of giving consent;
• To comply with applicable laws, regulations, and guidance; in the course of our legitimate interests.

4) How Long We Keep Your Personal Information

Le Sallay Academy will retain the Personal Data for no longer than it is necessary for the purposes as long as needed to provide the Services requested from Le Sallay Academy or requested by applicable laws and regulations. Beyond the above retention period, we will delete or anonymize your Personal Information.


5) How We Share and Disclose Your Personal Information

Within Le Sallay Academy, the Personal Information collected are only accessible to the members of Le Sallay Academy who, within the scope of their specific tasks, are responsible for it and whose access to these data is expressly required for the performance of their tasks.

We will never share or disclose your Personal Information without obtaining your consent unless when:

• It is directly relevant to national security or national defense security;
• It is directly relevant to public security, public health, or significant public interest;
• It is directly relevant to the investigation, prosecution, trial, and execution of a judgment of crimes;
• It is for the purpose of protecting life, property, or other significant legal rights and interests of Personal Data subjects or others, and it is difficult to obtain consents from such persons;
• The Personal Information collected has been disclosed by the Personal Data Subject to the public actively; or
• It is otherwise provided by applicable laws and regulations.

6) How Your Personal Information is Transferred

Subject to applicable local legal requirements, your Personal Information may be transferred, stored, and processed outside of the country where you live or have ordered our Services from, including to our subsidiaries, affiliated companies, and service providers located in other jurisdictions, and may become subject to the laws of such jurisdictions. The primary location of where your Personal Information will be stored or processed for the Services you have ordered from Le Sallay Academy will be stated in the governing contract and/or the test request form.

6.1) Transfer outside of EU
For Personal Information of Personal Data Subjects who are in EU: Le Sallay Academy will implement appropriate measures to ensure that Personal Information remains protected and secure when transferred outside the EU, in accordance with applicable data protection and privacy laws, such as:

• The country to which the Personal Data is transferred has benefited from an adequacy decision by the European Commission under Article 45 of the GDPR; or
• Standard data protection contractual clauses as approved by the European Commission pursuant to Article 47 of the GDPR have been established.

In the absence of the above appropriate safeguards, we will ask you for your explicit consent for cross-border transmission of your Personal Information. In the meantime, security measures such as encryption or de-identification will be adopted for the safety of your Personal Information.

7) How We Protect Your Personal Information

Le Sallay Academy uses a variety of security measures and technologies to help protect Personal Information from unauthorized access, use, disclosure, alteration, or destruction with applicable data protection and privacy laws.
Amongst others, when Le Sallay Academy shares the Personal Information of a Personal Data Subject with external suppliers/subcontractors or services providers, Le Sallay Academy may put in place a written agreement which commits the suppliers/sub-contractors or services providers to keep this Personal Information confidential and put in place appropriate security measures to keep this information secure.
Some of the safeguards we use to protect your information are firewalls, data encryption, and access controls. The administrative measures we use include the establishment of department and designation of the person responsible for the protection of Personal Information, conducting self-evaluation on the security of Personal Information, organization of training on relevant staff, etc.
In case of a Personal Information security incident, we will in a timely manner according to laws and regulations inform you about the basic conditions and possible influence of security incident, response measures that are already taken or to be taken by us, suggestions for you regarding precautions and risk control, corrective measures for you, etc. To the extent permitted by law, we will inform you about relevant situations of the incident in a timely manner via email, fax, telephone or any other means of communication we deem appropriate. When it is difficult to notify every Personal Data Subject individually, we will properly and effectively issue a public announcement.

8) Your Rights

We respect your legal rights with regards to your Personal Information. Below are the rights you may exercise before us by sending an email to info@lesallay.academy. Please note that for the sake of security, we may ask you to verify your identity before further processing your request.

• To access the Personal Information Le Sallay Academy hold about you: You are entitled to access and request copies of Personal Data that you provided to us unless applicable laws provide otherwise.
• To be informed about how Le Sallay Academy uses your Personal Information: We strive to be transparent about how we use your data. We keep you informed as to what we do with your Personal Data through this Privacy Policy.
• To have these data rectified promptly in case of inaccuracy/incompleteness: If you find that your Personal Information processed by us is inaccurate or incomplete, you are entitled to ask us to make rectifications.
• To have your Personal Information erased in specific circumstances: You can request us to delete your Personal Information if we do not have a legal reason to continue to process and hold it.
• To restrict the processing of your Personal Information: You have the right to ask us to restrict how we process your Personal Data. If you restrict our processing, we will not further process but are still permitted to store the data.
• To object to the processing of your Personal Information: You have the right to object to our processing your data even if it is based on our legitimate interests, the exercise of official authority, direct marketing (including data aggregation), and processing for the purpose of statistics.
• The right to data portability: To the extent permitted by laws and regulations, you have the right to request for the receipt of the transfer to another firm/organization in a structured, commonly used and machine-readable form of Personal Data provided to Le Sallay Academy.
• To lodge a complaint to Le Sallay Academy: You have the right to lodge a complaint by contacting info@lesallay.academy or to the local data protection authority if your privacy rights are violated or if you have suffered as a result of the unlawful processing of your Personal Information.

9) How We Process Children’s Personal Information

Although the definition of children varies according to laws and customs in different jurisdictions, we treat anyone under 16 years old (or the equivalent minimum age in relevant jurisdiction) as a child.
We will only collect and process Children’s Person Information after we have obtained explicit consent from their guardians. When we find that a child’s Personal Information is collected without the explicit consent of his or her guardian, we will delete the relevant data as soon as possible


10) How This Privacy Policy is Updated

Le Sallay Academy reserves the right to modify this Privacy Policy at any time in accordance with this provision. The circumstances where we may change our Privacy Policy including but not limited to: there is a major change of our service mode, e.g. purpose of processing Personal Information, type of processed Personal Information, usage mode of Personal Information; a major change in terms of our ownership structure, organization structure, e.g. change of owners due to business adjustment, bankruptcy, merging, etc.; change of the main object to which the Personal Information is publicly disclosed, shared, or transferred; change of your rights involved in Personal Information processing and their exercises; change of our responsible department, contacts and complaint channels for the security of Personal Information; when there is a high risk according to the Personal Information impact assessment report, etc.
If we make major changes to this Privacy Policy, we will post the revised Privacy Policy on our website and update the “Last Updated” date at the top of this Privacy Policy.


11) Contact Us

For any privacy concern, you may, at any time, contact us through info@lesallay.academy, and generally you will get our reply in twenty (20) working days or such shorter period as provided by law.