Privacy Policy

 
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25th May 2018

Hello dance friends and welcome to The 8 Elements’ Privacy Policy!

We are The 8 Elements, a belly dance training program developed and taught by Rachel Brice. The 8 Elements program falls under the Little Scarab, LLC business umbrella. Our headquarters is based in Portland, Oregon in the United States of America (1631 NE Broadway #617, 97232). Our Portland intensives are held at Studio Datura (1847 E Burnside, Ste #103, 97214) and NiaStudio (918 SW Yamhill St #401 97205).

Your privacy is of the utmost importance. We are fully committed to protecting your privacy rights.

Here are some terms you might see in our Privacy Policy:

  1. When we say “we”, “us”, “The 8 Elements” or “8 Elements” we’re talking about who we are. We own and run the training program or “Program”.
  2. When we say “event”, “intensive”, “training”, “phase”, we’re talking about a specific 8 Elements event. It can refer to one of the four phases (Initiation, Cultivation, Culmination, Transmission) of the 8 Elements program or 8 Elements continuing education, supplemental trainings, or related events.
  3. When we say “you”, “your”, “customer”, or “participant” we’re talking about you - the person engaging with our Program.
  4. If we say “Policy”, we’re talking about this Privacy Policy you are reading now. If we say “User Terms” we’re talking about the rules for participating in the “Program”.
  5. Both personal information and personal data have the same meaning in the context of this Privacy Policy.
  6. If you have any questions about this Policy, please feel free to contact us at anytime at the8elements@gmail.com.

By participating in The 8 Elements Program, you consent to the mandatory collection and use of your personal information as outlined in this Policy. As this Policy may be changed from time to time, you should visit this page regularly to review any changes to the Policy. We reserve the right to make changes to this Policy at any time and all changes to Policies will be posted on this webpage.

What do we use your personal information for?

We may use your name, email address and other information to:

  • Send you Program newsletters and announcements
  • Market products and services in the Program you may enjoy
  • Legally process your registration for the Program
  • Legally operate the Program
  • Provide you with services described on www.rachelbrice.com/about8elements
  • Carry out technical analysis to determine how to improve the content of the Program
  • Provide a more personalized experience and create a relationship with you by responding to your comments, questions, feedback, or participation in surveys
  • Respond to requests sent to us via email or facebook
  • Verify your identity when registering for subsequent phases of the Program
  • Inform you about changes to our Program and new products and services
  • Manage our legal and operational affairs
  • Train 8 Elements staff about how to best serve you and all our Program participants
  • Meet contractual obligations

What we do NOT use your personal information for:

  • We do NOT sell, trade or rent your personal information to others.
  • We do not use your personal information to make automated decisions.
  • We do not store your credit card details:
    • If you choose to register for the Program, your payment details are not stored by us and cannot be used by our staff.  Your payment details are processed via Eventbrite and Paypal. A copy of Eventbrite’s security policy is available here. A copy of Paypal’s privacy policy is available here.

    • If you choose to purchase 8 Elements merchandise via store.rachelbrice.com, payments are processed via Big Cartel and Paypal. A copy of Big Cartel’s privacy policy is available here.

    • If you register for retesting, payments are processed via Wufoo and Paypal. A copy of Wufoo’s privacy policy is available here.

The type of personal information we collect:

We collect certain personal information about participants of the Program.

When you sign up for our Mailing List or an intensive’s waitlist, we may ask you for personal information that we collect, such as:

  • Your name
  • Email address
  • Location
  • Other contact details
  • Survey responses
  • Feedback responses

When you register for an intensive, we may ask for for personal information that we collect, such as:

  • Your name
  • Email address
  • Location
  • Other contact details
  • Credit card or other payment information (which is maintained in encrypted form on secure servers through our payment processing services Paypal, Square Register, and Stripe to provide you the highest level of safety possible)
  • Application information that you submit to us
  • Emails you send to us
  • Comments or questions you ask us on facebook
  • Intensive Attendance data
  • Homework you submit
  • Intensive test registration, submissions, and results
  • Retesting registration, submissions, and results
  • Survey responses
  • Feedback responses
  • Other Rachel Brice events that you register for
  • Web analytics data

We may combine the information you submit under your account with information from other Little Scarab, LLC services or third parties in order to provide you with a better experience and to improve the quality of our services. For certain services, we may give you the opportunity to opt out of combining such information.

Finally, in order to provide the best possible service and to allow us to make certain internal reports and make recommendations, we collect aggregate information about the participation in the Program, including information about users accessing or viewing www.rachelbrice.com, such as:

  • Internet protocol addresses,
  • browser type,
  • browser language,
  • referring / exit pages and URLs,
  • other browser history,
  • platform type,
  • number of clicks,
  • domain names,
  • landing pages,
  • pages viewed and the order of those pages,
  • the amount of time spent on particular pages,
  • and the date and time ("Activity Information").

How do we collect your personal information?

1. Online cookies - When you visit www.rachelbrice.com or any of our third party sites (such as eventbrite.com, or purchase merchandise via store.rachelbrice.com), we send one or more cookies - a small file containing a string of characters - to your computer that uniquely identifies your browser. We use cookies to improve the quality of our Service by storing user preferences and tracking user trends. Additionally, we may use these cookies from Google’s Interest-based advertising or 3rd-party audience data (such as age, gender, location, and interests) with Google Analytics to show our ads on sites across the internet. Data collected via Google Analytics may be connected to other data that you provide us (including your location, program participation, and purchase history) to track user trends and for marketing purposes. Third-party vendors, including Google, use cookies may serve ads based on someone’s past visits to www.rachelbrice.com. Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Participants located in the USA can learn more about how to opt out of use of cookies here. Participants located outside of the USA can learn more here.  However, some online Program features and services may not function properly if your cookies are disabled.

2. IP Address - An IP address is a number that's automatically assigned to your computer whenever you're surfing the Web. We may retain your IP address in order to help us diagnose problems with our servers, to administer our Site, to help identify you, to gather broad anonymous demographic information (such as the number of website visitors from a geographic area), to enforce compliance with the Program terms and conditions, or otherwise in order to protect our services, sites, customers, or others.

3. User communications - When you send email or other communication to The 8 Elements, we may retain those communications in order to process your inquiries, respond to your requests and improve our services.

4. Affiliated sites - We may offer some of our services in connection with other websites. Personal information that you provide to those websites may be sent to us in order to deliver the service. We process such information in accordance with this Policy. The affiliated websites may have different privacy practices and we encourage you to read their privacy policies.

5. Links - The 8 Elements may present links in a format that enables us to keep track of whether these links have been followed. We use this information to track user trends and marketing, and to improve the quality of our Program offerings.

6. Other websites - This Policy applies to websites and services that are owned and operated on www.rachelbrice.com. We do not exercise control over third party websites we use, websites displayed as search results, or links from within our various services. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you.

The 8 Elements only processes personal information for the purposes described in the applicable Policy and/or privacy notice for specific services. In addition to the above, such purposes include:

  • Providing our products and services to participants,
  • Including the display of customized content and advertising;
  • Auditing, research and analysis in order to maintain, protect and improve our services;
  • Ensuring the technical functioning of our online offerings; and
  • Developing new services.

Where do we store your personal information?

The 8 Elements stores personal information on our servers in the United States of America. Depending on your activity and involvement with the program, personal information may also be stored on third party websites such as, but not limited to Eventbrite, MailChimp, CapsuleCRM, Wufoo, Big Cartel, Paypal, Square Space, and Square Register. In some cases, we may process personal information on behalf of and according to the instructions of a third party, such as our advertising partners.

How long is your personal information kept?

By participating in the Program, you consent to the collection and use of the above-described information.  We make efforts to ensure that all data retained remain accurate and current.

The length of time your personal information is kept is largely dependant on the type of information you have provided for us and your interactions with the program:

  • If you visit rachelbrice.com and consent to the use of cookies, we may retain your data for up to 5 years.
  • If you sign up for our mailing list, we may retain your data until you notify us you no longer wish to receive communications from us.
  • If you have taken a phase of the Program, we may retain your data for as long as the Program is active.  We do this for the integrity of the Program and for record-keeping purposes, and to ensure you receive credit for your academic acheivements.

Upon reaching the minimum retention period(s) that apply to the specific type of data stated above, we will securely delete personal information.

You may also change your preferences regarding how we use or disclose your information or request to have your personal data deleted or removed at any time by emailing us at the8elements@gmail.com.

How do we keep your personal information safe?

We take appropriate security measures to protect against unauthorized access to, or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data.

We restrict access to personal information. Access is restricted to Little Scarab, LLC employees, contractors and agents, who need the information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

All credit card or other payment account information which we collect is maintained in encrypted form on secure servers hosted by Eventbrite, Big Cartel, Wufoo, Square Register, Square Space, and Paypal, which provides Secure Sockets Layer protocol (SSL) with an encryption key length of 128 bits (the highest level commercially available) for all transactions. Additional documentation regarding privacy policies and transactions security of your information for each of the 3rd party service is linked in their names above, please review them for more details.

Data Integrity

The 8 Elements processes personal information only for the purposes for which it was collected and in accordance with this Policy or any applicable service-specific privacy notice. We review our data collection, storage and processing practices to ensure that we only collect, store and process the personal information needed to provide or improve our services. We take reasonable steps to ensure that the personal information we process is accurate, complete, and current, but we depend on our users to update or correct their personal information whenever necessary.

Accessing and Updating Personal Information

When you use The 8 Elements services, we make good faith efforts to provide you with access to your personal information and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests.  We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort.

Enforcement

The 8 Elements regularly reviews its compliance with this Policy. Please feel free to direct any questions or concerns regarding this Policy or The 8 Element's treatment of personal information by contacting us at the8elements@gmail.com

When we receive formal written complaints at the above address, it is The 8 Element's policy to contact the complaining participant regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between The 8 Elements and an individual.

Users Under 18

The 8 Elements’ content is not directed at participants under eighteen (18) years of age, and if you provide information about yourself as a participant of The 8 Elements, you are representing that you are at least eighteen (18) years of age.

We do not knowingly collect personally identifiable information from anyone under eighteen (18) years of age, but if we do become aware of having collected personally identifiable information from a user who is younger than eighteen (18) years of age, we will remove such information from our files.

Changes To This Policy

Please note that this Policy may change from time to time. We will not reduce your rights under this Policy without publicly posting such Policy changes on this page. If the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Policy changes). Each version of this Policy will be identified at the top of the page by its effective date, and we will also keep prior versions of this Privacy Policy in an archive for your review. As noted, The 8 Elements reserves the exclusive right and ability to institute changes at our sole discretion.

Third Party Links, Co-brand Relationships and Public Forums

In an attempt to provide increased value to our visitors, The 8 Elements may choose various third party web sites to link to, link from, and utilize to provide services to our participants. The 8 Elements also may participate in co-branding and other relationships to offer e-commerce and other services and features to its users. However, even if the third party is affiliated with The 8 Elements, we have no control over these linked sites, each of which have separate privacy and data collection practices independent of The 8 Elements. We have no responsibility or liability for these independent policies or actions, and are not responsible for the privacy practices or the content of any such web sites. Please make sure you are comfortable with the privacy practices of every site you visit before providing the site with your personal information. These linked sites are only for your convenience and you therefore access them at your own risk.

Third party sites that The 8 Elements uses include:

  • Eventbrite and Paypal (to process your registration payment information in encrypted form on secure servers)
  • Google Forms and Wufoo (to process voluntary feedback, applications, retesting registrations, test and retest submissions, and surveys)
  • Big Cartel and Paypal (to sell merchandise and process merchandise payment information in encrypted form on secure servers)
  • Facebook (to build a global community for our participants, answer participant questions, to share announcements and other program information, and for marketing purposes)
  • Google (for email communications, marketing, and analytics data and tracking)
  • CapsuleCRM (to assemble and manage information you willingly provide us in accordance with the terms set in this Policy)
  • YouTube and Vimeo (to collect practical test submissions and provide instructional videos to Participants)
  • Google Drive and Dropbox (to collect test submissions and homework)
  • Google Docs and Trello (to aid in our internal communications among Little Scarab LLC, employees)
  • We also may make event pages and groups available to you on Facebook. Please remember that we cannot control the information that is shared by participants and that anything you voluntarily provide in any public area of the Internet will be publicly available to other visitors on that web site and potentially to other third parties. Thus, please note that you should always exercise caution when deciding to publicly disclose any of your personal information in these and similar areas.

Choices For Personal Information:

When you sign up for the Program, we ask you to provide personal information. If we wish to use this information in a manner different than the purpose for which it was collected, then we will ask for your consent prior to such use.

If we propose to use personal information for any purposes other than those described in this Policy and/or in the specific service notices, we will offer you an effective way to opt out of the use of personal information for those other purposes. We will not collect or use sensitive information for purposes other than those described in this Policy and/or in the specific service notices, unless we have obtained your prior consent.

You can decline to submit personal information to any of our services, in which case The 8 Elements may not be able to provide those services to you.

Information Sharing

The 8 Elements only shares personal information with other companies or individuals outside of The 8 Elements in the following limited circumstances:

  • We have your consent. We require opt-in consent for the sharing of any sensitive personal information.
  • We provide such information to our subsidiaries, affiliated companies or other trusted businesses or persons for the purpose of processing personal information on our behalf (such as payment processing or interest-specific marketing). We require that these parties agree to process such information based on our instructions and in compliance with this Policy and any other appropriate confidentiality and security measures.
  • We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to: (a) satisfy any applicable law, regulation, legal process or enforceable governmental request; (b) enforce applicable Terms of Service, including investigation of potential violations thereof; (c) detect, prevent, or otherwise address fraud, security or technical issues; (d) provide a service that will aid in the delivery of Program content or help participants access and learn program materials; or (e) protect against imminent harm to the rights, property or safety of The 8 Elements, its users or the public as required or permitted by law.
  • If The 8 Elements becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will provide notice before personal information is transferred and becomes subject to a different privacy policy.
  • We may share with third parties certain pieces of aggregated, non-personal information, such information does not identify you individually.

Your Rights:

You have the right to be informed about how your personal information is used. You may check your information to verify, update, or correct it, and to have any obsolete information removed. If you would like to update your contact information, you can do so here. You can also ask to review any of the information we have retained, how we have used it, and to whom we have disclosed it at anytime by contacting us at the8elements@gmail.com.

Subject to certain exceptions prescribed by law, and provided we can authenticate your identity, you will be given reasonable access to your personal information, and will be entitled to challenge the accuracy and completeness of the information and to have it amended as appropriate. You may also change your preferences regarding how we use or disclose your information, let us know if you do not wish to receive any further communication from us, or request to have your personal data deleted or removed.

If you are a user or visitor in the European Economic area these rights also apply to you:

For the purposes of applicable EU data protection law (including the General Data Protection Regulation 2016/679 (the “GDPR”), we are a “data controller” of your personal information.

How you can contact us:

If you have any questions about our privacy practices or the way in which we have been managing your personal information, please contact us at 1631 NE Broadway #617, Portland, OR 97232, United States or the8elements@gmail.com.

The 8 Elements Terms of Service

Our current Terms of Service for 8 Elements intensives can be found here.  The 8 Elements' Terms of Service are expressly incorporated into this Policy by this reference.

Your consent

By participating in our Program, you consent to the collection and use of information by The 8 Elements as set forth in this Policy. If we decide to change our Policy, we will post those changes on this page so that you will always be aware of what information we collect, how we use it, and under what limited circumstances we disclose it.

This Policy applies to all of the products, services and websites offered by Little Scarab, LLC DBA The 8 Elements, an Oregon corporation (the "Program" or "8 Elements") any content or curriculum created by The 8 Elements or Rachel Brice and available through The 8 Elements or its subsidiaries or affiliated companies.

The 8 Elements Privacy Policy Effective Date 25 May 2018