PRIVACY POLICY

PREAMBLE

Otium Privacy Policy ("Privacy Policy") describes the ways in which Otium, Inc. ("Otium", "we", "us", or "our") collects, stores, uses, and protects information relating to an identified or identifiable natural person ("personal data") from users ("user" or "you") of our websites, mobile applications, and related services (collectively, the "Services"). This Privacy Policy is designed to comply with applicable data protection laws, including the General Data Protection Regulation ("GDPR") and other relevant legislation.

I. — DATA COLLECTED

We collect certain data from you directly, like information you enter yourself, data about your participation in courses, and data from third-party platforms you connect with Otium. We also collect some data automatically, like information about your device and what parts of our Services you interact with or spend time using.

1.1 — Data You Provide

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

Account Data

In order to use certain features (like enrolling in a course), you need to create a user account and provide us with your email address and, optionally, your name. If you choose to sign up using a social network account, such as Google, we may receive certain authentication data from the social network.

— Performance of contract; — Legitimate interests (identifying you as a user)

Profile Data

You can also choose to provide profile information like a photo, headline, website link, or other data. Your Profile Data will be publicly viewable by others.

— Performance of contract; and — Legitimate interests (identifying you as a user)

Shared Content

Parts of the Services may let you interact with other users or share content publicly, including by posting reviews on a course page, asking or answering questions, sending messages to instructors or other users, or posting photos or other work you upload.

— Performance of contract; and — Legitimate interests (helping you share content with others)

Learning Data

When you access content, we collect certain data including which courses, assignments, labs, workspaces, and quizzes you've started and completed; content purchases and credits; subscriptions; completion certificates; your exchanges with instructors, teaching assistants, and other students; and essays, answers to questions, and other items submitted to satisfy course and certification requirements.

— Performance of contract; and — Legitimate interests (to monitor platform activity)

Disciple Payment Data

If you make purchases, we collect certain data about your purchase (such as your name and zip code) as necessary to process your order. You must provide certain payment and billing data directly to our payment processing partners, including your name, credit card information, billing address, and zip code.

— Performance of contract Legal obligation

Praeceptor Payment Data

If you make purchases, we collect certain data about your purchase (such as your name and zip code) as necessary to process your order. You must provide certain payment and billing data directly to our payment processing partners, including your name, credit card information, billing address, and zip code.

— Performance of contract; — Legal obligation

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 Otium account. If you log in to Otium via Facebook or another third-party platform or service, we ask for your permission to access certain information about that other account.

— Legitimate interests (identifying you as a user)

Promotions and Surveys

We may invite you to complete a survey or participate in a promotion (like a contest, sweepstakes, or challenge), either through the Services or a third-party platform. If you participate, we will collect and store the data you provide as part of participating, such as your name, email address, date of birth, or phone number.

— Performance of contract Legitimate interests

Communication 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 like 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).

— Legitimate interests (customer service and analytics)

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

1.2 — Data Collected through Automated Means

When you access the Services (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.

— Performance of contract; and — Legitimate interests (service functionality, security, analytics)

Usage Data

Usage statistics about your interactions with the Services, including courses accessed, time spent on pages or the Service, pages visited, features used, your search queries, click data, date and time, referrer, and other data regarding your use of the Services.

— Legitimate interests (service functionality, personalization, analytics)

Approximate Geographic Data

An approximate geographic location, including information like country, city, and geographic coordinates, calculated based on your IP address.

— Legitimate interests (user experience, compliance, security)

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.

II. — HOW WE COLLECT DATA

We use tools like cookies, web beacons, and similar tracking technologies 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

We use cookies, which are small text files stored by your browser, to collect, store, and share data about your activities across websites, including on Otium. They allow us to remember things about your visits to Otium, like your preferred language, and to make the site easier to use. To learn more about cookies, visit https://cookiepedia.co.uk/all-about-cookies. We may also use clear pixels in emails to track deliverability and open rates.

2.2. — Purposes of Data Collection

We use cookies, which are small text files stored by your browser, to collect, store, and share data about your activities across websites, including on Otium. They allow us to remember things about your visits to Otium, like your preferred language, and to make the site easier to use.

III. — USE OF YOUR DATA

We use your data to do things like provide our Services, communicate with you, troubleshoot issues, secure against fraud and abuse, improve and update our Services, analyze how people use our Services, serve personalized advertising, and as required by law or necessary for safety and integrity. We retain your data for as long as it is needed to serve the purposes for which it was collected.

IV. — DATA SHARING

We share certain data about you with instructors, other students, companies performing services for us, our business partners, analytics and data enrichment providers, social media platforms, companies helping us run promotions and surveys, and advertising companies who help us promote our Services. 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 with your consent.

V. — 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 contact us if you suspect any unauthorized access to your account.

VI. — RIGHTS

You may have certain rights around the use of your data, including the ability to opt out of promotional emails, cookies, and collection of your data by certain third parties. You can update or terminate your account from within our Services, and can 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 for help deleting that information.

6.1 . — 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.

6.2. — Accessing, Updating, and Deleting Your Personal Data

You can access and update your personal data that Otium collects and maintains through your account settings. To delete your account, contact us at correspondance@o-tium.com.

6.3. — 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. Individuals younger than 18 years of age, but of the required age for consent to use online services where they live (for example, 13 in the US or 16 in Ireland), may not set up an account, but may have a parent or guardian open an account and help them access appropriate content.

VII. — JURISDICTION-SPECIFIC RULES

7.1. — Users in California

Users who are California residents have certain rights under the California Consumer Privacy Act, ("CCPA"). If you are an eligible California user, included in these rights are the right to know, right to delete, right to correct, and the right to opt-out of sale/sharing.

7.2. — Users in Nevada

Otium does not sell its users' personal data or personal information. If, in the future, Otium decides to sell your personal information, you will have the right to opt out.

7.3. — Users in Australia

If you are an Australian resident, your personal data may be processed outside of Australia, including in the United States and other countries. We take steps to ensure that our service providers are bound by obligations to protect your personal data.

7.4. — Users in the European Economic Area, Switzerland, and United Kingdom

If you are located in the EEA or Switzerland, you have certain rights under GDPR, including the right to access, rectify, restrict processing, object to processing, data portability, and erasure of your personal data. You also have the right to lodge a complaint with a supervisory authority.

7.5. — Data Privacy Framework Notice

The types of personal data collected, the purposes for which personal data is collected and used, the types of third parties to which Otium discloses personal data and the purposes for doing so, and the rights of individuals regarding their personal data are described above in this Privacy Policy.

7.6. — Outside Users

In order to provide the Services to you, we must transfer your data to our servers in the United States and other countries. By using Otium, you authorize us to transfer your data internationally.

VIII. — UPDATES & CONTACT INFO

8.1 — Modifications to This Privacy Policy

From time to time, we may update this Privacy Policy. If we make any significant changes, we'll provide prominent notice by posting a notice on the Service or by sending you an email.

8.2. — Interpretation

Any capitalized terms not defined in this Privacy Policy will have the meaning set forth in our 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 control.

8.3. — Questions

You can contact Otium to: correspondance@o-tium.com

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