Classical Conversations, Inc
United States Privacy Policy
Last Updated: 09-16-2024
Welcome to the family of websites and services provided by Classical Conversations, Inc. (“CCI,” “we,” “us,” or “our”). In this U.S. Privacy Policy (“Privacy Policy”), we describe how we collect, use, disclose, and protect your Personal Information when you visit our websites, including https://classicalconversations.com (the “Websites”); purchase or interact with our curriculum offerings, subscriptions, and audio or visual content (the “Services”); and when you otherwise interact with us.
We may modify this Privacy Policy at any time in our sole discretion. Material changes will be conspicuously posted on the Websites, at the top of this Privacy Policy, or otherwise communicated to you. All changes will be effective immediately upon posting to the Websites.
IF YOU ARE A CALIFORNIA OR TEXAS RESIDENT, PLEASE SEE THE “YOUR STATE PRIVACY RIGHTS” SECTION BELOW FOR ADDITIONAL INFORMATION THAT APPLIES TO YOU.
1. WHAT IS PERSONAL INFORMATION?
For purposes of this Privacy Policy, “Personal Information” means information that alone or in combination identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information does not include publicly available information or de-identified or aggregated information that does not include personal identifiers.
2. CATEGORIES OF PERSONAL INFORMATION WE COLLECT
We provide below the categories of Personal Information we collect, examples of the data elements in those categories and information regarding our retention practices:
| Category | Examples | Retention Period |
|---|---|---|
| Identifiers | Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number (for employment purposes), passport number (for purposes of international events), or other similar identifiers, students’ date of birth (for programming and transcript service purposes), physical characteristics or description | We retain Identifiers as long as we have a business relationship with you. When you provide us with Identifiers related to your job application or your employment, we keep that information as required by applicable law. |
| Customer Records | Insurance policy number, bank account number, financial information, medical information, or health insurance information | We retain this information for so long as we have a business relationship with you or as required by applicable law. |
| Protected Classifications | Race, religion, sex, gender, gender identity/expression, sexual orientation, marital status, medical condition, veteran status, country of residence and current citizenship, ancestry, disability, genetic information, request for family care leave, leave for own’s serious condition, or pregnancy disability leave, age (over 40); employee birth dates | As required by law. |
| Commercial Information | Records of Products or services purchased, obtained, or considered | We maintain records of these transactions for approximately 7 years from the date of the transactions. |
| Internet or other network activity information | IP Address, Device ID | So long as needed for our business purposes. |
| Geolocation Data | Imprecise geolocation data such as your city, state, zip code, and country (based on IP Address) | For so long as required for our business purposes. |
| Employment Information | Employment dates, history, and previous employers | As required by law. |
| Education Information | Information provided in resumes and job applications, including employment history.
Information provided to us in connection with contracts with licensees and local representatives. |
As required by law. |
| Inferences | We may use personal information to understand a consumer’s purchasing history and purchases considered or other purchasing or consuming histories, predispositions or tendencies. | For so long as required for our business purposes. |
| Sensitive Personal Information | Social security number and passport number; race, religion, mental or physical health diagnosis, sexuality, or citizenship or immigration status, and genetic or biometric information; account log-in, number in combination with any required security or access code or password; the personal Information of children | For so long as required for our business purposes. |
3. SOURCES OF PERSONAL INFORMATION THAT WE COLLECT
We collect Personal Information from the following sources:
Information We Collect from You
We collect Personal Information from you directly when you:
- Place an order on our Websites;
- Return or exchange a product;
- Ask questions about our products and services or otherwise contact us;
- Interact with our Live Chat feature on our Websites or the AI-powered chatbot on our Social Media pages;
- Create an account on the Websites;
- Sign up for emails, updates, or promotions;
- Apply for a job;
- Enter into a contract to perform services for us;
- Solicitation or negotiation of contracts
- Participate in a survey, promotion, or event.
Information We Collect Automatically
When you browse our Websites. If you browse our Websites, regardless of whether you create a user account, purchase any products, or otherwise interact with the Websites, CCI logs your IP address (the internet address of your computer) to tell us which parts of the Websites you visit and how long you spend on those pages. We will also track the state and/or country from which you are accessing the Websites, the date and time you visited the Websites and the type of computer or another electronic device, operating system, and web browser you are using.
Google Analytics
Cookies & other tracking technologies. We use cookies, web beacons, pixels and other tracking technologies (collectively “Cookies”) when you use our Websites to operate our site, to collect analytics data and to serve targeted advertising. To learn more about how we use Cookies and your options to limit the data collected from our Websites, see the section titled “Cookies, Analytics and Personalized Advertising, and Your Privacy Choices” below.
Information We Collect From Third-Party Sources
We may collect information from third party sources including:
- Affiliates such as our partner organizations, affinity partners, and community leaders
- From other customers and members
- From service providers who provide data enrichment services; and
- From our analytics providers and targeted advertising providers.
4. PURPOSE FOR WHICH WE COLLECT PERSONAL INFORMATION
We collect certain Personal Information from for the purposes described below.
| Purpose for Collection and Use | Examples | Category of Data |
|---|---|---|
| Communication Purposes |
|
|
| For Product Orders |
|
|
| Website and Account Management Purposes |
|
|
| Marketing & Advertising Purposes |
|
|
| For Business, Compliance, and Legal Purposes |
|
|
| Analytics |
|
|
5. DISCLOSING PERSONAL INFORMATION
We may disclose your Personal Information as follows:
| Those With Whom We Disclose Personal Information | Purpose for Disclosing | Category of Information |
|---|---|---|
| Affiliates and Subsidiaries |
|
|
| Service Providers |
|
|
| Third-Party Advertising Networks, Analytics Providers and Social Media Platforms | We share data with third party advertising networks to provide you with targeted advertising and other marketing communications, including on social media sites. These partners also perform data and statistical analysis for us. |
|
| Government and Law Enforcement | We will cooperate with law enforcement and other governmental agencies, and may disclose Personal Information: (i) if we believe in good faith we are legally required to disclose that Personal Information, (ii) if we are advised to disclose Personal Information by our legal counsel, or (iii) when necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, CCI, its employees, its member or any other person or entity. | All Categories |
| Professional Advisors | We may share your Personal Information to receive advice from our professional advisors, such as our attorneys, accountants, financial advisors, insurance brokers and business advisors, in their capacity as advisors to us. | All Categories |
| New Owners or Successors in Interest | We may share your Personal Information in connection with a contemplated or completed strategic business transaction such as a merger, acquisition, sale of all or substantially all of our assets or stock to a subsequent owner or operator, a dissolution, bankruptcy, liquidation or other similar business transaction where personal information may be shared, sold or transferred to that third party, including during the due diligence process. | All Categories |
| With Your Consent | We may share Personal Information in other ways if you give us consent or direct us to do so. | All Categories |
De-Identified / Aggregated Data
We may aggregate or de-identify Personal Information we collect through our Websites and when operating our business. For example, we may aggregate Personal Information to calculate the percentage of users in a particular zip code. Once information or data has been de-identified and/or aggregated, such information is no longer considered Personal Information. We take reasonable measures to ensure that the deidentified data we possess cannot be associated with an individual and commit to maintaining and using deidentified data without attempting to reidentify it.
CCI may use or share such de-identified or aggregated data for any legal purpose as determined in its sole discretion, and the use and disclosure of such information is not subject to this Privacy Policy.
6. COOKIES, ANALYTICS AND PERSONALIZED ADVERTISING, AND YOUR PRIVACY CHOICES
How We Use Cookies
We and certain third parties who provide analytics services or targeted advertising use Cookies to collect information about your activity, browser, and device when you visit our Websites. We use Cookies to:
- Remember your preferences when you visit our Websites and allow you to enter your username less frequently;
- Uniquely identify each user session when you access the Websites;
- Compile aggregated statistics to analyze how the Websites are used;
- Present you with personalized, or targeted advertising, including our content presented on other websites and across devices; and
- Measuring the effectiveness of our Websites, content, communications, and advertising, including by placing web beacons (sometimes called single-pixel gifs) that let us know which emails and links have been opened by recipients.
Analytics and Advertising
We use third-party services on our Websites that help us deliver personalized advertisements to you across your devices, including those specified below.
Google Analytics and Its Advertising Features. Google Analytics is a third-party service that transmits website traffic data to Google servers in the United States. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand the Websites’ traffic and web page usage. We have enabled and implemented the following Google Analytics Advertising Features: DoubleClick and Google Dynamic Remarketing. To opt-out of the use of this data by Google Analytics, you can follow the instructions to download and install the Google Analytics Opt-out Browser Add-on for each web browser you use. Using the Google Analytics Opt-Out Browser Add-On will not prevent us from using other analytics tools and will not prevent data from being sent to the Websites themselves or to Google. Opting out will not affect your use of the Websites. For more information on how Google uses Personal Information, visit Google’s Privacy Policy and Google’s page on How Google uses data when you use our partners’ sites or apps.
Facebook/Meta. We use Facebook Connect and Facebook Custom Audience to deliver targeted advertisements to website visitors on Facebook based on email addresses that we have collected. Facebook Connect and Facebook Customer Audience use the Meta Pixel, which collects your internet browsing information in order to display our advertisements to you on the Meta platform and help us gain insights on and improve our advertising. For more information about Facebook’s privacy practices, please refer to their privacy policy. To opt out, please visit here.
Session Replay:
Microsoft Clarity and Hotjar. We have implemented and use session replay software, including software offered by Microsoft Clarity and Hotjar. The session replay software allows us to collect information about how you navigate and use our Websites in real-time. Microsoft Clarity and Hotjar collect information including the date and time you visited the Websites, mouse clicks, mouse movements, keystrokes and text input, scrolling, webpage or content loading times and site errors. Other Personal Information these targeted advertising partners collect includes IP addresses, browser information, device IDs, operating system, cookie and customer IDs.
HubSpot. We use HubSpot on our Websites to collect analytical data. HubSpot sets Cookies which collect certain data, specifically IP address, location, browser, duration of the visit, and accessed websites. HubSpot evaluates this data to provide us information about our Websites and provides our Customer Relationship Management software.
Microsoft Ads. We may use Microsoft Ads (formerly known as Bing Ads), an online marketing service provided by Microsoft, to display search advertisements and to track when you have visited our Websites via a Microsoft Ads advertisement. For information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement. If you click on a Microsoft Ads advertisement, Microsoft Ads stores a cookie on your device that is used to track the number of individuals who click on a Microsoft Ads advertisement and are forwarded to the applicable website. To learn more about Microsoft’s privacy practices, please refer to their privacy policy, available here. Microsoft allows you to opt out of tracking associated with Microsoft Ads. You may opt-out here.
Your Privacy Choices
Updating your information through your account settings. You may access and update most of your Personal Information if you have an account on our Websites. If you need to access, update, or delete other Personal Information that we may have, please visit your account settings under “My Account,” sending a request to opt-out@classicalconversations.com.
Disabling Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can choose to disable cookies on your browser, but doing so may prevent you from using the full features of the Websites. You cannot disable all cookies, such as cookies that are essential to the functioning of the Websites. You can learn how to opt out of some of those cookies by accessing the Network Advertising Initiative’s website at https://optout.networkadvertising.org or the Digital Advertising Alliance’s website at https://optout.aboutads.info. For more information on mobile-specific opt-out choices, please visit https://www.networkadvertising.org/mobile-choices from your mobile device. Changing your settings with individual browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads.
Opt Out of Marketing Emails. If you sign up to receive electronic communications, you consent to our sending such electronic communications to you using the email address you provide. If you no longer want to receive electronic marketing communications from us, please use the “unsubscribe” button found on the emails you received. Within ten (10) days of receipt of your unsubscribe request, we will remove you from our distribution list unless you request to be added again in the future.
Opt Out of Marketing Text Messages. If you would like to opt out of text alerts, you may text “STOP” in the text message thread at any time to no longer receive marketing messages. Please note that you still may receive text messages regarding your order status or other transactional data that is not related to marketing if you have previously opted in.
7. ADDITIONAL INFORMATION ON OUR PRIVACY PRACTICES
Access from Outside the United States
If you access the Websites from outside the United States, please be aware that Personal Information will be transferred to, stored in, and processed in the United States. Certain governmental authorities may not consider the level of protection of Personal Information in the United States to be equivalent to that required by the in other jurisdictions. Please do not use our Websites if you are outside the United States.
Data Security
We use reasonable physical, technical and organizational measures to help secure Personal Information against unauthorized access or acquisition appropriate to the type of Personal Information processed. If a breach of your Personal Information occurs, we will notify you of the breach if required under applicable law.
Third-Party Websites
The Websites may link to, or be linked to, websites not owned or controlled by CCI. CCI is not responsible for the privacy policies or practices of any third parties or any third-party websites. This Privacy Policy does not apply to any third-party websites or to any Personal Information that you may provide to third parties. You should read the privacy policy for each website that you visit.
Social Media
We are active on social media, including Facebook, YouTube, X (formerly Twitter), Instagram, Pinterest and LinkedIn (“Social Media”). Your interactions with us and other users on Social Media is public information and will not be treated confidentially. We may post on the Websites and our Social Media pages or otherwise disclose any comments or content that you submit on or through our Social Media pages. Your use of Social Media is governed by the privacy policies and terms of the third parties that own and operate those websites. We encourage you to review those policies and terms.
YouTube. We use the YouTube application programming interface (API) Services to allow you to access YouTube content from our Websites. Your use of YouTube is governed by YouTube’s Terms of Service and Privacy Policy and not by our Terms of Use or Privacy Policy.
Children
The Websites are not directed at children under 16 years of age. We do not knowingly collect, use, share or sell Personal Information from children under 16. If a parent or legal guardian learns that their child provided us with Personal Information without his or her consent, please contact us and we will make commercially reasonable attempts to delete such Personal Information. We may collect children’s data from a parent when enrolling their child in our curriculum offerings.
8. CONTACT US
If you have any questions, comments, or concerns about this Privacy Policy or our privacy practices, please contact us using any of the following methods:
| Mail: | Classical Conversations, Inc. 255 Air Tool Drive Southern Pines, NC 28387 |
|---|---|
| Phone: | 910-430-5197 |
| Email: | opt-out@classicalconversations.com |
9. YOUR STATE CONSUMER PRIVACY RIGHTS: TERMS APPLICABLE TO CALIFORNIA AND TEXAS RESIDENTS ONLY
Under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act and its implementing regulations (together, the “CCPA”) and the Texas Data Privacy and Security Act (“TDPSA”), residents of California and Texas have additional rights regarding their Personal Information. We have provided a summary of those rights below. In the event of a conflict between this Section and the remainder of this Privacy Policy, this Section shall take precedence for the applicable state residents.
Certain capitalized terms not defined in this Privacy Policy have the meanings set forth in the CCPA or TDPSA, as applicable.
Your State Consumer Privacy Rights
Right to Know or Access Your Personal Information
You have the right to confirm whether we are processing your Personal Information and to access such Personal Information.
Right to Request the Deletion of Personal Information
You have the right to request that we delete Personal Information we have collected from or about you. We will comply with such request, and direct our service providers to do the same, subject to certain exceptions permitted by applicable law.
Right to Correct Your Personal Information
You have the right to request that we correct your inaccurate or outdated Personal Information. If you request that we correct Personal Information about you, we will use commercially reasonable efforts to correct it. If necessary, we may ask that you provide documentation showing that the information we retained is inaccurate or outdated. If you have an account with us, we may ask you to sign into your account for verification.
Right to Data Portability
You may request a copy of the Personal Information you previously provided to us in a portable, and, to the extent technically feasible, readily usable format.
Right to Non-Discrimination
California and Texas residents have the right to be treated in a non-discriminatory manner for exercising any of their rights under their respective state privacy laws.
California-Specific Rights and Disclosures
Right to Access Categories of Personal Information
California residents have the right to access any of the following which occurred in the previous 12 months:
- The categories and specific pieces of Personal Information that we have collected from you;
- The categories of sources from which the Personal Information was collected;
- The categories of third parties to whom we have disclosed your Personal Information;
- The categories of Personal Information that we Sold/Shared or disclosed for a Business Purpose and the categories of third parties to whom it was disclosed for a Business Purpose; and
- The Business or Commercial Purpose for collecting, sharing, or selling your Personal Information.
Right to Opt Out of the Sale or Sharing of your Personal Information
California residents may opt out of the sale or sharing of their Personal Information. For more information, please see the section titled, “Your California Right to Opt Out of the Sale or Sharing of Personal Information,” below.
Disclosing Personal Information
During the past 12 months, we have disclosed the following categories of Personal Information for a Business Purpose:
- Identifiers, Customer Records, Commercial Information, Internet Activity, Geolocation Data, Employment information, Education information, and Inferences
Selling and Sharing Personal Information
In the last 12 months we have not Sold your Personal Information to a third party for monetary compensation. Our use of Cookies and other technologies to deliver targeted advertising and for analytics purposes may be considered the “Sharing” of Personal Information under the CCPA. We may Share the following categories of Personal Information with third parties that provide us with targeted advertising or data analytics services.
- Identifiers, Internet Activity, Geolocation Data
Your California Right to Opt Out of the Sale or Sharing of Personal Information
California residents have the right to opt out of the sale or sharing of their Personal information. You may authorize another person to submit requests to exercise this right on your behalf.
If you are a California resident, you may opt out of the above described uses of your Personal Information by:
- Emailing us at: opt-out@classicalconversations.com
- Completing our webform at: Exercise Your Right To Opt Out
You must provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information, and you must describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to your request.
If you choose to use an Authorized Agent, you must (a) provide signed, written permission that authorizes the Agent to submit requests on your behalf and (b) verify your identity directly with us or (c) directly confirm with us that you granted permission to the Authorized Agent to submit the request on your behalf. For clarity, you are required to verify the identity of both you and the Authorized Agent. We may deny a request from an Authorized Agent if we do not have proof that they are authorized by you to act on your behalf.
Additionally, you may opt-out by broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.
Texas-Specific Rights
Right to Opt Out of Certain Processing of Your Personal Information
Texas residents may opt out of the processing of their Personal Information for purposes of: i) targeted advertising, ii) the sale of their Personal Information, and iii) automated profiling of Personal Information, if that profiling could lead to certain legal outcomes, (i.e., the provision or denial of education enrollment or employment opportunities).
You may use an Authorized Agent to opt out of the sale of their Personal Information and the processing of their Personal Information for the purposes of targeted advertising.
Exercising Your State Privacy Rights
Who May Exercise Your Rights. You may make a request to exercise your state privacy rights. A parent or legal guardian may make a request on behalf of their child. Under the CCPA, California residents may authorize another person to submit requests to exercise their rights on their behalf (an “Authorized Agent”). Under the TDPSA, Texas residents may use an Authorized Agent to opt out of the sale of their Personal Information and the processing of their Personal Information for the purposes of targeted advertising. If you choose to use an Authorized Agent, you must (a) provide signed, written permission that authorizes the Agent to submit requests on your behalf and (b) verify your identity directly with us or (c) directly confirm with us that you granted permission to the Authorized Agent to submit the request on your behalf. For clarity, you are required to verify the identity of both you and the Authorized Agent. We may deny a request from an Authorized Agent if we do not have proof that they are authorized by you to act on your behalf.
Verifiable Consumer Requests. To verify your request, you must provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information, and you must describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to your request.
When we receive your request to exercise your rights: (a) we will acknowledge receipt of your request; (b) we will try to match the information you provide in making the request with information we already maintain about you; (c) if required to verify your identity, we may ask you to provide additional information, including personal information, or to log into your existing account with us; (d) we will consider various factors when determining how to verify your identity, such as the sensitivity and value of the data, the risk of harm, the likelihood of fraud, etc.
We will only use the Personal Information we collect during the verification process for the purpose of verifying your identity. If we are unable to verify your identity as required by applicable laws and regulations, we will decline to comply with your request and let you know why.
Submitting Requests. You may exercise your privacy rights up to two times per year at no charge to you. We have the right to charge a fee for subsequent requests or any request that is manifestly unfounded, excessive, or repetitive. To exercise your rights described in this Section, you may submit your request to us by contacting us at any of the following:
| Mail: | Classical Conversations, Inc. 255 Air Tool Drive Southern Pines, NC 28387 |
|---|---|
| Phone: | 1-888-862-0613 |
| Email: | opt-out@classicalconversations.com |
When We Will Respond. We will try to respond to your request within 45 days. If we require additional time, we will inform you of the reason and extension period. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. For data portability requests, we will select a format to provide your Personal Information to you. We may charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded.
Appeals Process for Texas Residents
If you are a Texas resident, you have the right to appeal a denied request to exercise your privacy rights. You must submit your request within 60 days of your receipt of our denial. You may submit your request to us by:
| Emailing us at: | opt-out@classicalconversations.com |
|---|---|
| Mailing us: | Classical Conversations, Inc. 255 Air Tool Drive Southern Pines, NC 28387 |
| Or by phone: | 1-888-862-0613 |
When We Will Respond. We will respond to your appeal within 60 days of receiving your request. When we respond we will include any action taken or not taken, including an explanation of the reason or reasons for the decision.
California’s Shine the Light
Pursuant to California Civil Code Section 1798.83, if you are a California resident, you have the right to obtain: (a) a list of all third parties to whom we may have disclosed your Personal Information within the past year for direct marketing purposes, and (b) a description of the categories of Personal Information disclosed, by contacting us per the “Contact Us” Section above.