January 4, 2023

Welcome to Ideanco, a community marketplace.  The ideanco website and service including (without limitation) www.ideanco.com and subdomain of ideanco.com (the “Site”) and all subdomain websites such as academy.ideanco.com, lab.ideanco.com, advisory.ideanco.com, mobile applications and other interactive properties through which the service is delivered (collectively, the “Services”) are owned, operated and distributed by Ideanco., LLC., a Delaware corporation (referred to in this Privacy Policy as “Ideanco” or “we” and through similar words such as “us,” “our,” etc.).

General

At Ideanco. LLC. (“ideanco.”), a registered trademark “ideanco.®”, your privacy is important to us. This Privacy Policy (“Privacy Policy”) explains the information we collect when you visit the Site. It also explains how you can exercise your data protection rights concerning that information. This Privacy Policy is developed for you to understand how we collect, use, communicate, disclose, and use Personal Data (as defined below).

By accessing any part of the Services, you are agreeing to the terms and conditions described below with this Privacy Policy and the terms and conditions of our terms of service (the “Terms of Service”). If you do not agree to any of these terms, you should not use the Services. This Privacy Policy applies to all users, including both users who are simply viewing content available via the Services and users who have registered as members (“Dreamers”) of Ideanco.

When your register with us and become a Member of ideanco., when you choose to teach or attend a class, we will ask you for Personal Data. “Personal Data” refers to information about you that can be used to contact or individually identify you. This includes, but is not limited to, your name, and email address, but does not include your credit card number or billing information. Transactions on the Site or Services involving your billing and payment information are processed by Stripe and are subject to their privacy policies. We do not store any of the credit card or banking information that you provide to these payment processors.

We may, at our sole discretion, modify this Privacy Policy at any time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make material changes in the way we collect or use information, we will notify you by posting an announcement on the Services or sending you an email. By accessing the Services at any time after such modifications, you are agreeing to be bound by the updated policy. This Privacy Policy was initiated on July 4, 2020. By using the Site, you acknowledge that you have read and understood our Privacy Policy.

This Privacy Policy is intended to help you understand:

1. What Data We Get
2. How We Use Your Data We Collect
3. How We Disclose Personal Data
4. How We Secure Information
5. Data Retention
6. Your Rights to Your Personal Information
7. Use by Minors
8. How We Transfer Information Internationally
9. Other Important Privacy Information

1. What Data We Get

We collect certain data from you directly, like the information you enter yourself, data about your participation in courses, and data from third-party platforms you connect with Ideanco (if there is any third party engaged). We also collect some data automatically, like information about your device and what parts of our Services you interact with or spend time using. Information gathered on our website can come to us in the following ways:

Information you provide:

When you communicate with ideanco through the Site or Services through the Site, register with us and become an ideanco Member, and when you choose to teach or attend a class, we will ask you for Personal Data. “Personal Data” refers to information about you that can be used to contact or individually identify you. This information may include feedback you provide to us or requests for assistance.  Information shared with us via the Site or Services may include first name,  last name, email address, company name, and job title but does not include your credit card number or billing information. When you enroll in and take courses, we collect certain data including which courses, assignments and quizzes you’ve started and completed; your exchanges with instructors, teaching assistants, and other dreamers; and essays, answers to questions, and other items submitted to satisfy course requirements. Parts of the Services let you interact with other users or share content publicly, including by posting reviews on a course page, asking or answering questions, sending messages via that or messages tools to dreamers or instructors, or posting photos or other work you upload. Such shared content may be publicly viewable by others depending on where it is posted. 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. For security, transactions on the ideanco Site involving your billing and payment information are processed by Stripe and are subject to their privacy policies. We do not store any of the credit card or banking information that you provide to these payment processors. We may obtain certain information through your social media or other online accounts if they are connected to your account at Ideanco.

Information provided by others:

To the extent permitted by applicable law, we may receive additional information about you from other sources such as partners, researchers or marketers.  We may combine information that we collect from you with information about you from such sources and use it in accordance with this Privacy Policy. Ideanco Site is prepared to have social media signup from trusted and reputable third-party platforms, and if you signup to Ideanco Site via Google, LinkedIn or using Apple ID or another third-party platform or service, we ask for your consent to access certain information. Depending on the platform or service we may collect your name, profile picture, account ID number, login email address, location, the physical location of your access devices, gender, birthday, and list of friends or contacts, since such platforms 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 Services or Site 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 particular third party.

Information we collect automatically

When you visit the Site or Services (including browsing courses), the server log files and tracking technologies as indicated in the Cookies and Other Tracking Technologies Tools, automatically record information that your browser sends whenever you visit a website (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, and an approximate geographic location, including information like country, city, and geographic coordinates, calculated based on your IP address, browser type, browser software version, the webpage you were visiting before you came to our Site, pages of our Site that you visit, the time spent on those pages, the information you search for on our Site or Services, access times and dates, and usage statistics about your interactions with the Site or Services, including courses accessed, time spent on the Site or Services, pages visited, features used, your search queries, click data, date and time, and other data regarding your use of the Site or Services. We may correlate this Log Data with other information we have about you.

Cookies and Other Tracking Technologies Tools

We and our third-party service providers acting on our behalf (like Google Analytics, analytics partners and third-party advertisers) use cookies and other tracking technologies (e.g., web beacons, tags, customized links, and device identifiers) to collect information about your activities over time and across different aspects of the Site or Services, customize your experience, remember actions from your browsing session, provide relevant advertising, and improve the quality of the Site or Services. For detailed information about the use of cookies on the Site, please read our Cookie Policy.

We use the following types of Cookies:

• Necessary Cookies. Necessary Cookies are required for providing you with the features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Site or Services. Disabling these Cookies may make certain features and services unavailable.
• Security: cookies are used to enable you to log in and access the Services; protect against fraudulent logins; and help detect and prevent abuse or unauthorized use of your account.
• Functionality Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These cookies help us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).
• Session State: cookies that track your interactions with the Services to help us improve the Services and your browsing experience, remember your login details, and enable processing of your course purchases. These are strictly necessary for the Services to work properly, so if you disable them then certain functionalities will break or be unavailable.

We use third-party advertising services like Facebook, Google’s ad services, and other ad networks and ad servers to deliver advertising about our Site or Services on other websites and applications you use. The ads may be based on things we know about you, like your Log Data, and things that these ad service providers know about you based on their tracking data. When using mobile applications you may also receive tailored in-app advertisements. Apple iOS, Android OS, and Microsoft Windows each provide 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.

To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit https://ico.org.uk/for-the public/online/cookies/ or http://www.allaboutcookies.org/.

2. How We Use Your Data We Collect

We use your data:

To advance the Site or Services and personalize your experience, we use information about you to provide, update and improve the Site or Services, communicate with you, troubleshoot issues, respond to your comments, questions and requests, secure against fraud and abuse, serve personalized advertising, and as required by law or necessary for safety and integrity, and provide customer support. We connect with you about your account by:

• Answering your enquiries and distributing managed information, including communication or messages from instructors, announcements about changes to our Site or Service, and updates to our agreements;
• Sending you information and in-app messages about your progress in courses, rewards programs, new services, new features, promotions, newsletters, and other available courses (which you can opt-out of at any time);
• Directing push notifications to your wireless device to provide updates and other relevant communications (which you can manage from the “options” or “settings” page of the mobile app);

To market, promote and initiate engagement with the Site or Services, we use the information collected from you via our Site or Services and from third parties to send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about us or partner campaigns and services) and social media advertising through social media platforms (such as Google, Facebook, Instagram, YouTube and LinkedIn). We learn about you by:

• Market and administer surveys and promotions administered or sponsored by Ideanco.
• Linking your data with additional data through third-party data providers or analyzing the data with the help of analytics service providers;
• Tailor advertisements across devices;
• Advertise the Site and/or Services on third-party websites and applications;

These communications are aimed at driving engagement and informing you of new features (product features), offerings or events relevant to the Site or Services, we think may be of interest to you.

To satisfy legal and regulatory requirements, where we have a legal obligation or where we believe it is necessary to protect our legal rights or interests or the interests of others, we may use information about you in connection with legal claims or compliance, regulatory, and audit functions. If you are a visitor from the European Economic Area (“EEA”) or the United Kingdom (“UK“), our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

We may have other legitimate interests and if appropriate we will disclose such interests at the relevant time.

3. How We Disclose Personal Data

We may share certain data we collect from you with instructors and/or consultants, other dreamers, and third parties as described in this Privacy Policy or as indicated below:

With service providers: We share Personal Data with a limited number of our service providers to help us provide services related to the Site or Services. We have service providers that provide services on our behalfs, such as identity verification services, website hosting, data analysis, information technology and related infrastructure, customer service, email delivery, auditing services, system infrastructure, data storage, customer database management, email marketing, marketing analytics and online chat. These service providers may need to access Personal Data to perform their services. We authorize such service providers to use or disclose the Personal Data only as necessary to perform services on our behalf or comply with legal requirements. We require such service providers to contractually commit to protecting the security and confidentiality of the Personal Data they process on our behalf. Our service providers are predominantly located in the European Union and the United States of America.

Business partners. We share Personal Data with third-party business partners when this is necessary to provide our Services to our Users.

With Your Instructors: We share Personal Data with the instructors for classes (“Instructors”) that you sign up for so that they can coordinate their classes. As part of our Terms of Use, our Instructors agree not to abuse other users’ Personal Data. Abuse is defined as using Personal Data for any purpose other than those explicitly specified in the Instructor Guideline. However, please understand that our Instructors are not our employees or consultants and that we are not a party to any transaction between you and the Instructor. As a result, we cannot control their actions and cannot be held liable for any actions that they may take.

With Other Dreamers and Instructors: Depending on your settings, your shared content and profile data may be publicly viewable, including to other dreamers and instructors within each course or each Webinar. If you ask a question to an instructor or teaching assistant, your information (including your name) may also be publicly viewable by other users depending on your settings.

With Analytics and Data Enrichment Services: As part of our use of third-party analytics tools like Google Analytics and data enrichment services, we share certain contact information, Log Data, or de-identified data as needed.

To Administer Promotions and Surveys: we may share your data as necessary to administer, market, or sponsor promotions and surveys you choose to participate in, as required by applicable law (like to provide a winners list or make required filings), or in accordance with the rules of the promotion or survey.

In addition, we may provide Personal Data to employees, consultants or other businesses or persons to process such information on our behalf. In such circumstances, we require that these parties agree to protect the confidentiality of such information and to comply with the terms of this Privacy Policy. We may use your Personal Data to operate, improve, understand and personalize our Services.

During a Change in Control: Where we are negotiating with a potential buyer in connection with any proposed merger or sale of any part of our business (Site and/or Services), we may provide your personal information to the proposed buyer (and its agents and advisers) provided that we inform the buyer that it must use your personal information only for the purposes disclosed in this Privacy Notice.

In compliance with law, responding to legal requests, preventing harm and protection of our rights: Though we employ industry standard measures to preserve user privacy, we may need to disclose Personal Data when required by law or when we have a good faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process, or law enforcement or governmental authorities, or authorized third parties that we receive or to protect our interests or the safety of others, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against ideanco., (iii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to enforce and administer our terms and conditions, or (v) to protect the rights, property or personal safety of ideanco., its employees, its users, or members of the public. We also share Personal Data when we believe it is necessary to:

• Protect us, our business or our users, for example, to enforce our terms of service, preventing spam or other unwanted communications and investigating or protecting against fraud.
• Maintain the security of our products and services

With your consent: We will not give your name, email, or other Personal Data to unaffiliated third parties except with your consent or as otherwise outlined in this privacy policy.

Lastly, we can share data in other ways if it is aggregated or de-identified or if we get your consent.

4. How We Secure Information

We take appropriate technical and organizational measures to protect your personal information from and against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, and access. Unfortunately, however, no system can be 100% secured, so we cannot guarantee that communications between you and ideanco., the Site or Services, or any information provided to us in connection with the data we collect through the Site and/or Services 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 support@ideanco.com with any concerns.

We use state-of-the-art Secure Socket Layer (SSL) encryption technology to safeguard and protect your personal information and transactions over the internet. Your information, including your credit card information, is encrypted and cannot be read as it travels over the Internet.

5. Data Retention

We take appropriate technical and organizational measures to protect your Personal Data from and against accidental or unlawful destruction for as long as you have an open account with us or as otherwise necessary to provide you Services. In some cases, we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us or ceased using your ideanco account.  We retain information derived from cookies and other tracking technologies for a reasonable period from the date such information was created.

Please note: We do not retain the Personal Data of the user(s) who do not verify their account after registering (Signing up) and such Personal Data is deleted. User(s) who have registered (Sign up) and verified their account are members (“Dreamers”) of Ideanco, and such Personal Data is retained and protected under this Privacy Policy.

6. Your Rights to Your Personal Information

You have certain rights concerning your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email  help@ideanco.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request. Parents who believe we’ve unintentionally collected personal data about their underage child should contact us for help deleting that information.

• Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by emailing help@ideanco.com.
• Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by making changes to your Profile. You can request that we correct or supplement such data by emailing help@ideanco.com.
• Erasure: You can request that we erase some or all of your Personal Data from our systems by emailing help@ideanco.com.
• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
• Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
• Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
• Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
• Right to File Complaint: You have the right to lodge a complaint about ideanco’s practices concerning your Personal Data with the supervisory authority of your country or EU Member State. If you are located in the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (“GDPR”) concerning your Personal Data, as outlined in the EU Privacy Policy
• Opting out of receiving electronic communications from us. If you no longer want to receive marketing-related emails from us, you may opt out via the unsubscribe link included in such emails. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages that are required to provide you with our Services.

7. Use by Minors

All references to “child” or “children” refer to children under the age of 13. The Services are not directed to individuals under the age of thirteen (13), and we request that they do not provide Personal Data through the Services.

Children’s Privacy

Ideanco will only request the parent and/or legal guardian to complete the Parent/Legal Guardian Consent Form of a child on courses designated for children under the age of 18. The information that is collected will only be used for the requested purpose and will be deleted after such use.

We recognize the privacy interests of children and encourage parents and legal guardians to take an active role in their children’s online activities and interests. If we learn that we’ve collected personal data from a child under those ages (Children under 13 or 16 in the European Economic Area) without the parent/legal guardian’s consent, we will take reasonable steps to delete it.

Use of Personal Information Collected from Children

When we collect personal information from children under the age of 16, we will only use that information for the express purpose for which it was collected and in particular for the educational courses designed for such age.  The personal information will not be used for any other purpose.

Sharing of Personal Information Collected from Children

Ideanco does not share personal information collected from children with any third parties.  Please note: If we become aware that we have unintentionally received personally identifiable information from a user under the age of thirteen other than in a legally permissible situation, we will delete the information from our records as soon as we discover it.

Important Note to Parents and Legal Guardians

Please contact ideanco at any time regarding privacy questions or concerns, or to request to review what personal information we have collected from a child. Parent(s)/Legal Guardian(s) may also contact us at any time to request that we delete the personal information of a child or a parent and/or refuse to permit further collection or use of a child’s information. Ideanco complies with the steps developed internally to verify that any person contacting us for a child’s information is that child’s parent or legal guardian. For any further inquiries, please contact:

Ideanco

One World Trade Center

Suite 8500

New York, NY 10007

United States

Tel: +1 212-763-0036

Email: privacy@ideanco.com

U.S. School-based Users

We do not knowingly gather or seek Personal Data from anyone under the age of 16. If you are a high school student and are opening/accessing the Site or Services through an account provided by your school (a “U.S. School-based User”), you may only access the Site or Services if you are at least 13 years old.

8. How We Transfer Information Internationally

The Services are hosted and operated in the United States (“U.S.”) through ideanco. and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Site or Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to ideanco. in the U.S. and will be hosted on U.S. servers, you authorize ideanco. to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S. as set forth herein.

9. Other Important Privacy Information

Links to Other Sites

The Services may contain links to other websites or services. We are not responsible for the privacy practices or the content of such websites or services, and you should review the privacy policy of each such website or service to make sure that you are comfortable with it before providing any Personal Data.

Forums And Chats
We may offer forums and chat rooms. Please be aware that anyone may read postings on a forum or in a chat room. Furthermore, any information which is posted to a forum or chat room could include personal information, which would be disclosed and available to all users of that forum or chat room within a particular virtual classroom, and is therefore no longer private. We cannot guarantee the security of information that any user discloses or communicates online in public areas such as forums and chat rooms. Those who do so, do so at their own risk. We reserve the right to monitor the content of the forums and chat rooms. If age-inappropriate content or potentially identifiable information is seen, it may be removed or edited by us for security, privacy, and/or legal reasons. We will not republish postings from forums or chat.

Interaction with the Community Members

Ideanco is simply providing a platform in which to connect, learn and socialize online with fellow participants within the Site or Services. Dreamers are solely responsible for interactions (including any disputes) with other member Dreamers and will exercise caution, discretion, common sense, and judgment in using the various ideanco Services and disclosing personal information to other Dreamers, members or users.

Voluntary Disclosure

Any Personal Data or content that you voluntarily disclose in public areas becomes publicly available and can be collected and used by other users for any reason. Your profile pages (“Profile”) and any online classrooms you participate in are typically publicly available. You can change your account settings to limit access to your profile and may delete content you post to public classrooms. If you need assistance with controlling your account privacy settings or with deleting content, please contact us at help@ideanco.com. Removal of posted content does not ensure complete or comprehensive removal of the content or information (e.g., some content may be “invisible” to other users but remain on our servers in some form). You should exercise caution before disclosing your Personal Data via these or any other public venues.

Credit Card Information and Transactions

We do not store any of the credit card or banking information that you provide to these payment processors.

Users Outside of the U.S.

Ideanco., LLC. is based in New York, and to provide the Services to you, we must transfer your data to the United States and process it there. By visiting or using our Services, you consent to the storage of your data on servers located in the United States. If you are using the Services from outside the United States, you consent to the transfer, storage, and processing of your data in and to the United States or other countries. Specifically, personal data collected in the United Kingdom (“UK”), Switzerland, and the European Economic Area (“EEA”) is transferred and stored outside those areas. Additionally, if you are located in the UK, EEA, or Switzerland, you also have the right to lodge a complaint with your data supervisory authority. That data is also processed outside of the UK, Switzerland, and the EEA by our ideanco, or our service providers, including processing transactions, facilitating payments and providing support services. 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 Services, you consent to this transfer, storage, and processing by ideanco and its processors.

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 Services, or as required by applicable law. We will also 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 Services 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.