STUDIOJJK PRIVACY POLICY[last updated December 30, 2020]

Thank you for visiting www.studiojjk.com and thejjkblog.blogspot.com (collectively, the “Website”) This privacy policy (the “Policy”) aims to describe how StudioJJK, LLC (“we,” “us,” “our”) collects and uses personal information that visitors provide to us on our Website, which helps children reach their highest creative potential.

PRIVACY PRINCIPLES

We provide safe, entertaining and educational content on the Website, while recognizing and respecting the importance of privacy, especially for children, in this digital environment.

The Website’s primary function is to provide visitors with information. When users visit the Website, we may collect personal information in two forms. One form is information that we expressly request visitors to provide which may be necessary for the performance of a contract in connection with certain activities (such as enrolling in courses or signing a waiver and release form before uploading user-submitted content) or based on your consent or based on our legitimate interest (which is not overridden by your data protection interests), such as for research and development, and to protect our legal rights and interests. The second form is anonymous information that we automatically collect from the visitor’s computer, phone or other device.

Our Policy is based on the following principles:
1. You are free to choose whether or not to engage in any activity on the Website that involves your submission of personal information, such as your name, email address, or other information that can be used to identify or contact an individual, whether online or offline. We will ask you for such information expressly. Most of the activities on our Website do not require you to submit any personal information.
2. When we ask you to submit personal information, we will explain in the sign-up or collection process how we will use the information. We will use the information only as we describe, other than in Special Circumstances which are described below (such as in relation to law enforcement or a business transfer), and retain such information for no longer than is necessary, and, except as otherwise described in this Policy, we will not allow data to be processed by any third parties without your prior consent. Visitors who would like to object to our processing of their data, or otherwise access, rectify, erase (under certain circumstances), or transfer their personal data should email us at manager@studiojjk.com. Visitors have the right not to be subject to a decision based solely on automated data processing. 
3. We use the anonymous information that is automatically collected from your device, such as a computer's Internet Protocol address, a mobile device identifier, operating system, or general location such as zip code, to support internal operations so that we can understand, monitor, and improve the Website’s performance.
4. There is no behavioral advertising on the Website, which means that you will not see any advertising that is targeted to you based on your combined activity on the Website and your activity on other sites and apps.
5. Third parties that we use to assist with the Website are required to follow this Policy.

CHILDREN UNDER 13

6. Our collection of personal information on the Website may include information of children under 13 years old. This Policy is intended to follow the principles of the Children's Online Privacy Protection Act ("COPPA"), a U.S. law designed to protect the online privacy of children under the age of 13.
7. We will obtain parental consent before asking for personal information on our Website, unless the request for information falls within an exception that would be permitted under COPPA.
8. We do not make personal information collected from children publicly available nor do we enable children to so on the Website. Parents may have the option to opt-in to the disclosure of some of their child’s personal information, such as their child’s age and name, for example in association with user-submitted content. As any user-submitted content may be publicly displayed, parents agree that any personal data contained in any such submissions may be made public. We will not condition a child's participation in any activity or service on the disclosure of more personal information than is reasonably necessary to participate in an activity.
9. Parents may contact us at manager@studiojjk.com) to review, update or delete any of their children's personal information that we may have collected and to elect for us not to collect any additional personal information from their children.

10. We may update this Policy from time to time by posting the updated Privacy Policy online. We will attempt to provide you with reasonable advanced notice of such a change before it goes into effect. We will not change how we handle previously collected information without providing notice and obtaining parental consent where necessary.

INFORMATION WE REQUEST ON THE WEBSITE

We will obtain parental consent before accepting user-submitted content, or asking for personal information on our Website, unless the request for information falls within an exception that would be permitted under COPPA. We will explain why your information is needed in order for us to provide a service to you and how we will use the information, and we will use it only for that purpose. Here are examples of personal information that we may request on the Website:

• Submitting User-Submitted Content. When visitors to the Website wish to upload files containing user-submitted content, such as artwork made by children, we will ask for a parent’s full name and birthdate. If the birthdate submitted would render the caretaker less than eighteen years old, the submission will automatically fail and all information related to such submission attempt will be deleted. 

INFORMATION WE COLLECT AUTOMATICALLY

We use the anonymous information that is automatically collected to support the internal operations of the Website. Some of this information is collected through third-party analytics tools. Internal operations include the following:

• to monitor metrics such as total number of visitors and traffic on the Website;
• to understand which activities and services are most popular;
• to understand the pages where visitors enter the Website and the pages viewed;
• to recognize the browsers used to visit the Website, so that the content is adapted for the relevant browser; and
• to diagnose and fix technology problems.

When you visit the Website, we may use cookies and similar technologies like pixels and web beacons, to collect this anonymous information for the purpose of the internal operations of the Website. A "cookie" is a piece of information that a web site or an app transfers to a user's device for record-keeping purposes. As a user moves from one page or one screen to another, a cookie is used to tell us that it is the same device. We also may use a cookie to keep track of your selections. You may set your device to accept or not accept cookies and you may delete any cookies that you have received. However, should you decide to disable any cookies we place on your device, you may not be able to use certain services or features on the Website. A "web beacon" is a one-pixel image (which may be visible or transparent), which may be embedded on a web page or e-mail message, and which may also provide us with information about usage of that page or e-mail message.

SPECIAL CIRCUMSTANCES

Law Enforcement and Safety. We may access, preserve and share your information when we have a good faith belief that it is necessary to: (i) respond to a legal request (like a search warrant, court order or subpoena) or otherwise take action that we believe it is required or advisable under the law; (ii) detect, prevent and address fraud and other illegal activity; (iii) respond to your requests for customer service; or (iv) limit our legal liability or to protect the rights, property, or personal safety of ourselves, any user of the Website, a third party or the general public including as part of investigations.

Business Transfer. If we sell or otherwise transfer part or the whole of StudioJJK, LLC or our assets to another organization (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution or liquidation), your personal information, and any other information collected through the Website may be among the items sold or transferred. The buyer or transferee will be required to honor the commitments we have made in this Policy.

Security Notice. In the unlikely event that we believe that the security of your personal information in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we would endeavor to do so as promptly as possible under the circumstances, and, to the extent you have given us your e-mail address, we may notify you by e-mail. You consent to our use of e-mail as a means of such notification.

SERVICE PROVIDERS

We contract with third parties to provide certain services to facilitate the operations of the Website ("Partners"), such as to manage the analytics information about usage of the Website, to facilitate online classes, or to process orders. Our Partners will be given access to your information only as is reasonably necessary to provide the services for which they are contracted. They will be required to abide by the terms of this Policy in their handling of personal information.

WHERE WE STORE YOUR INFORMATION

Your information collected through the Website may be stored and processed in the United States or any other country in which we or our Partners maintain facilities. We or our Partners may transfer information that we collect about you, including personal information, across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. By using the Website you consent to the transfer of information to the U.S. or to any other country in which we or our service providers maintain facilities and the use and disclosure of information about you as described in this Policy.

SECURITY OF YOUR INFORMATION

We strive to maintain the security of information but cannot guarantee that information security measures are fail-safe or guarantee that information on the Website may not be accessed, disclosed, altered, or destroyed. We maintain technical and organizational steps to keep information collected secure, including limiting the number of people who have physical access to our database servers and use of electronic security systems and password protections to guard against unauthorized access.

OTHER WEB SITES AND SERVICES

The Website may link to other websites or apps, including content offered by third parties that we do not control and whose privacy and data collection practices may differ from ours ("Third Party Platforms"). We are not responsible for the practices employed by any websites or services linked to or from the Website, including the information or content contained within them.

When you go via our link to Third Party Platforms, you become subject to their terms of use and privacy policies rather than ours. We strongly urge you to carefully review the privacy policy for any website to understand how your personal information may be collected and processed.

StudioJJK Store. The StudioJJK Store is facilitated by various Partners who are licensees that have each entered into agreements with us to operate at least some portion of the StudioJJK Store and to sell and ship products related to StudioJJK. When you click on items in the Studio JJK Store, you will be redirected to a Partner’s website in order to complete your purchase. Any personal information you provide to such a Partner on their website is subject to the Partner’s privacy policy.

ONLINE SAFETY

Remaining aware of your family’s online activities is a critical safety tool. The federal government also provides resources to help you and your children practice good privacy hygiene while online. We recommend that you review the following guidance: https://www.consumer.ftc.gov/articles/0031-protecting-your-childs-privacy-online

CALIFORNIA USERS

The Website is controlled, operated and administered from our offices within the Commonwealth of Massachusetts. If you access the Website from a location in California or are a resident of California, you are responsible for compliance with all local laws. You agree that you will not use any content accessed through the Website in any manner prohibited by any applicable laws, restrictions or regulations. 

If you are a California resident, you may have certain rights, effective as of January 1, 2020.
 We will take reasonable steps to verify your identity before responding to requests to delete or provide personal data, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your (or your parent’s) name and email address.

You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.
 We do not collect or sell personal data from residents of California. Any information you voluntarily provide, such as an email address, can be removed upon request.

STUDIOJJK, LLC CONTACT INFORMATION

You can reach out to us with questions or complaints at:
StudioJJK, LLC, P.O. Box 1541, Easthampton, MA 01027, USA. manager@studiojjk.com