APP Privacy

Key Information

.. · Image by Kelz LLC is the data controller of your personal information.

.. · We collect the personal information set out in the "What Information We Collect" section of this Privacy Policy below, including account registration details, details of online courses you undertake, survey information (where you provide it), identity verification data and information about your use of our application and services.

.. · We use your personal information for the purposes set out in the "How We Use the Information" section of this Privacy Policy below, including providing our application and services to you, ensuring the security and performance of our application, research relating to academic courses, sharing information with our partners (such as academic institutions) and our suppliers, direct marketing and performing statistical analysis of the use of our application and services.

.. · You have a number of rights that you can exercise in relation to our use of your personal information, as set out in the "Updating or Deleting Your Personally Identifiable Information" section of this Privacy Policy below.

You can find information about us and how we collect, use and store your personal data in each section of this privacy policy:

● Purpose and who we are

● What Information this Privacy Policy Covers

● What You Agree by Using Our Application

● What information We Collect

● Information Collection and Use

● How We Use the Information

● External Links

● Retention of Personally Identifiable Information

● Confidentiality & Security of Personally Identifiable Information

● Updating or Deleting Your Personally Identifiable Information

● Questions, Suggestions and Complaints

● Changing Our Privacy Policy

● No Information from Children Under 13

No Information from Children Under 13

Purpose and who we are

The purpose of this Privacy Policy is to describe how Image by Kelz LLC,"The IBK Way" ("us," "we," or "our") collects, uses and shares information about you through our online interfaces (e.g., mobile applications) owned and controlled by us, including www.imagebykelz.com (collectively referred to herein as the "Application"). Please read this notice carefully to understand what we do. If you do not understand any aspects of our Privacy Policy, please feel free to contact us at info@balticbrows.com. Your use of our Application is also governed by our Terms of Use. Image by Kelz LLC is a company with a principal place of business at S. Daukanto g. 26, Kaunas, Lithuania. If you reside or are located in the European Economic Area ("EEA") Image by Kelz LLC is the data controller of all Personally Identifiable Information (as defined below) collected via the Application and of certain Personally Identifiable Information collected from third parties, as set out in this Privacy Policy.

What Information this Privacy Policy Covers

This Privacy Policy covers information we collect from you through our Application. Some of our Application’s functionality can be used without revealing any Personally Identifiable Information, though for features or services related to the Online Courses, Personally Identifiable Information is required. In order to access certain features and benefits on our Application, you may need to submit, or we may collect,

"Personally Identifiable Information" (i.e., information that can be used to identify you). Personally Identifiable Information can include information such as your name and email address, among other things. If you reside or are located in the EEA, it can also include your IP address or device identifier. You are responsible for ensuring the accuracy of the Personally Identifiable Information you submit to Image by Kelz LLC. Inaccurate information may affect your ability to use the Application, the information you receive when using the Application, and our ability to contact you. For example, your email address should be kept current because that is one of the primary manners in which we communicate with you.

What You Agree to by Using Our Application

We consider that the legal bases for using your personal information as set out in this privacy policy are as follows:

.. · our use of your personal information is necessary to perform our obligations under any contract with you (for example, to comply with the terms of use of our Application which you accept by browsing our application and/or to comply with our contract to provide services to you); or

.. · our use of your personal information is necessary for complying with our legal obligations; or

.. · where neither of the above apply, use of your personal information is necessary for our legitimate interests or the legitimate interests of others. Our legitimate interests are to:

.. ⚬ run, grow and develop our business;

.. ⚬ operate our Application and provide our services;

.. ⚬ select appropriately skilled and qualified suppliers;

.. ⚬ build relationships with partners and academic institutions;

.. ⚬ carry out research and statistical analysis;

.. ⚬ carry out marketing and business development; and

.. ⚬ for internal administrative and auditing purposes.

If we rely on our (or another person's) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person's) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information.

We may process your personal information in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time after giving it, as described below).

If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by contacting us to delete your account and we will delete it. However, if you withdraw your consent, this may impact the ability for us to be able to provide our services to you.

What Information We Collect

We gather two types of information about users through the Application:

1.Information relating to your use of our Application. When users come to our Application, we may track, collect and aggregate information indicating, among other things, which pages of our Application were visited, the order in which they were visited, when they were visited, and which hyperlinks were "clicked." We also collect information from the URLs from which you linked to our Application. Collecting such information may involve logging the IP address, operating system and browser software used by each user of the Application. We may be able to determine from an IP address a user’s Internet Service Provider and the geographic location of his or her point of connectivity. We also use (or may use) cookies and APP beacons when you visit our Application. For more information on our use of cookies and APP beacons, please refer to our Cookie Policy.

2. Personally Identifiable Information provided directly by you or via third parties. We collect Personally Identifiable Information that you provide to us when you register for an account, update or change information for your account, purchase products or services, complete a survey, sign-up for email updates or Online Courses, participate in our public forums, send us email messages, and/or participate in Online Courses or other services on our Application. We may use the Personally Identifiable Information that you provide to respond to your questions, provide you the specific course and/or services you select, send you updates about Online Courses offered by Image by Kelz LLC and events, and send you email messages about Application maintenance or updates.

.. · Account Registration. If you register for an account on our Application, you may be required to provide us with Personally Identifiable Information such as your name and email address.

.. · Updates. Image by Kelz LLC may offer you the ability to receive updates either via email or by posting on portions of the Application only accessible to registered users. In order to subscribe to these services, you may be required to provide us with Personally Identifiable Information such as your name and email address.

.. · Participation in Online Courses. Image by Kelz LLC offers users the opportunity to participate in an Online Course. If you desire to participate in a course, you will be asked to provide us with certain information necessary to conduct such a course. This information may include, among other things, your name and email address.

If you participate in an online course, we may collect your certain student-generated content, such as assignments you submit to instructors. We also collect course data, such as student exams, and surveys. You should not include any Personally Identifiable Information or other information of a personal or sensitive nature, whether relating to you or another person, on assignments, exams, or surveys, except for information required to participate or submit such assignments, exams, or surveys.

.. · Identity Verification. Image by Kelz LLC may offer you the ability to verify your identity for selected classes. In order to enroll for these services, you may be required to provide us or our third-party identity verification vendor with Personally Identifiable Information such as your name, address, date of birth, a headshot taken using a cam.

.. · Communications with Image by Kelz LLC. We may receive Personally Identifiable Information when you send us an email message or otherwise contact us.

.. · Third Party Applications. We may receive Personally Identifiable Information when you access or log-in to a third party application, e.g., Facebook, from our Applications. This may include the text and/or images of your Personally Identifiable Information available from the third party application.

.. · Surveys. We may receive Personally Identifiable Information when you provide information in response to a survey operated by us. This may include details about your race, your education history, and your employment.

.. · Third Party Credit Card Processing. Image by Kelz LLC provides you with the ability to pay for Online Courses and other services using a credit card through a third party payment processing service provider (www.paypal.com). Please note that our service provider (www.paypal.com) – not Image by Kelz LLC – collects and processes your credit card information.

Information Collection and Use

For a better experience, while using our Service, we may require you to provide us with certain personally identifiable information, including but not limited to first and last names, email address, profile picture, device diagnostic data, crash reports data, analytics, courses purchase history, homework, messages, biography, statistics, certificates, logos, etc.. The information that we request will be retained by us and used as described in this privacy policy.

The app does use third party services that may collect information used to identify you.

Link to privacy policy of third party service providers used by the app

How We Use the Information

1.Information relating to your use of our Application. We use information relating to your use of the Application to build higher quality, more useful services by performing statistical analyses of the collective characteristics and behavior of our users, and by measuring demographics and interests regarding specific areas of our Application. We may also use this information to ensure the security of our services and the Application.

2.Personally Identifiable Information provided directly by you or via third parties. Except as set forth in this Privacy Policy or as specifically agreed to by you, Image by Kelz LLC will not disclose any of your Personally Identifiable Information. In addition to the other uses set forth in this Privacy Policy, we may disclose and otherwise use Personally Identifiable Information as described below.

.. · Providing the Application and our services. We use Personally Identifiable Information which you provide to us in order to allow you to access and use the Application and in order to provide any information, products or services that you request from us.

.. · Technical support and security. We may use Personally Identifiable Information to provide technical support to you, where required, and to ensure the security of our services and the Application.

.. · Updates. We use Personally Identifiable Information collected when you sign-up for our various email or update services to send you the messages in connection with the Application or an Online Course. We may also archive this information and/or use it for future communications with you, where we are legally entitled to do so.

.. · Participation in Online Courses. We use the Personally Identifiable Information that we collect from you when you participate in an Online Course through the Application for processing purposes, including but not limited to tracking attendance, progress, and completion of an Online Course. We may also share your Personally Identifiable Information and your performance in a given Online Course with the instructor or instructors who taught the course, with teaching assistants or other individuals designated by the instructor or instructors to assist with the creation, modification or operation of the course, and with the institution or institutions with which they are affiliated. Also, we may archive this information and/or use it for future communications with you, where we are legally entitled to do so.

.. · Communications with or from Image by Kelz LLC. When you send us an email message or otherwise contact us, we may use the information provided by you to respond to your communication and/or as described in this Privacy Policy. We may also archive this information and/or use it for future communications with you where we are legally entitled to do so. Where we send you emails, we may track the way that you interact with these emails (such as when you open an email or click on a link inside an email). We use this information for the purposes of optimizing and better tailoring our communications to you.

.. · Communications with Image by Kelz LLC Business Partners. We may share your Personally Identifiable Information with University partners and other business partners of Image by Kelz LLC so that our partners and other business partners may share information about their products and services that may be of interest to you where they are legally entitled to do so.

.. · Research. We may share general course data, information about your activity on our Application, and demographic data from surveys operated by us with our partners so that our partners may use the data for research related to online education.

.. · Disclosure to Image by Kelz LLC Operations and Maintenance Contractors. We use various service providers, vendors and contractors (collectively, "Contractors") to assist us in providing our products and services to you. Our Contractors may have limited access to your Personally Identifiable Information in the course of providing their products or services to us, so that we in turn can provide our products and services to you. These Contractors may include vendors and suppliers that provide us with technology, services, and/or content related to the operation and maintenance of the Application. Access to your Personally Identifiable Information by these contractors is limited to the information reasonably necessary for the contractor to perform its limited function for us.

.. · Government Authorities, Legal Rights and Actions. Image by Kelz LLC may share your Personally Identifiable Information with various government authorities in response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights or to protect our property; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us. We also may share your Personally Identifiable Information when we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of Image by Kelz LLC, the Application, our users, customers, or others; and in connection with our Terms of Use and other agreements.

.. · Disclosure to Acquirers. Image by Kelz LLC may disclose and/or transfer your Personally Identifiable Information to an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of the equity, business or assets of Image by Kelz LLC to which your Personally Identifiable Information relates.

.. · e-Readers. If we receive any Personally Identifiable Information related to the extent to which you use designated e-Readers to access Image by Kelz LLC materials, we may archive it, and use it for research, business, or other purposes.

External Links

For your convenience we may provide links to applications operated by organizations other than Image by Kelz LLC("Third Party Applications") that we believe may be of interest to you. We do not disclose your Personally Identifiable Information to these Third Party Applications unless we have a lawful basis on which to do so. We do not endorse and are not responsible for the privacy practices of these Third Party Applications. If you choose to click on a link to one of these Third Party Applications, you should review the privacy policy posted on the other application to understand how that Third Party Application collects and uses your Personally Identifiable Information.

Retention of Personally Identifiable Information

If you reside or are located in the EEA, we keep your Personally Identifiable Information for no longer than necessary for the purposes for which the Personally Identifiable Information is processed. The length of time we retain Personally Identifiable Information for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.

Confidentiality & Security of Personally Identifiable Information

We consider the confidentiality and security of your information to be of the utmost importance. We will use industry standard physical, technical and administrative security measures to keep your Personally Identifiable Information confidential and secure and will not share it with third parties, except as otherwise provided in this Privacy Policy, or unless such disclosure is necessary in special cases, such as a physical threat to you or others, as permitted by applicable law. Because the Internet is not a 100% secure environment we cannot guarantee the security of Personally Identifiable Information, and there is some risk that an unauthorized third party may find a way to circumvent our security systems or that transmission of your information over the Internet will be intercepted. It is your responsibility to protect the security of your login information. Please note that e-mails communications are typically not encrypted and should not be considered secure.

Updating or Deleting Your Personally Identifiable Information

You have certain rights in relation to your Personally Identifiable Information. You can access your Personally Identifiable Information and confirm that it remains correct and up-to-date or choose whether or not you wish to receive material from us or some of our partners by logging into the Application and visiting your user account page.

If you would like further information in relation to your rights or would like to exercise any of them, you may also contact us via contact@imagebykelz.com. If you reside or are located in the EEA, you have the right to request that we:

.. · provide access to any Personally Identifiable Information we hold about you;

.. · prevent the processing of your Personally Identifiable Information for direct-marketing purposes;

.. · update any Personally Identifiable Information which is out of date or incorrect;

.. · delete any Personally Identifiable Information which we are holding about you;

.. · restrict the way that we process your Personally Identifiable Information;

.. · provide your Personally Identifiable Information to a third party provider of services; or

.. · provide you with a copy of any Personally Identifiable Information which we hold about you. We try to answer every email promptly where possible, and provide our response within the time period stated by applicable law. Keep in mind, however, that there will be residual information that will remain within our databases, access logs and other records, which may or may not contain your Personally Identifiable Information. Please also note that certain Personally Identifiable Information may be exempt from such requests in certain circumstances, which may include if we need to keep processing your Personally Identifiable Information to comply with a legal obligation. When you email us with a request, we may ask that you provide us with information necessary to confirm your identity.

Questions, Suggestions and Complaints

If you have any privacy-related questions, suggestions, unresolved problems, or complaints you may contact us via contact@imagebykelz.com.

Changing Our Privacy Policy

Please note that we review our privacy practices from time to time, and that these practices are subject to change. Any change, update, or modification will be effective immediately upon posting on our Application. We will notify you of any material change to this Privacy Policy by posting a notice on our Application’s homepage for a reasonable period of time following such update, and by changing the effective date. Be sure to return to this APP periodically to ensure familiarity with the most current version of this Privacy Policy.

No Information from Children Under 13

Image by Kelz LLC strongly believes in protecting the privacy of children. In line with this belief, we do not knowingly collect or maintain Personally Identifiable Information on our Application from persons under 13 years of age, and no part of our Application is directed to persons under 13 years of age. If you are under 13 years of age, then please do not use or access this Application at any time or in any manner. We will take appropriate steps to delete any Personally Identifiable Information of persons less than 13 years of age that has been collected on our Application without verified parental consent upon learning of the existence of such Personally Identifiable Information.

Contact Us

Please contact us with any questions or comments about this Privacy Policy, transfer of your personal information to our privacy practices, or your consent choices by email contac@imagebykelz.com