Privacy Policy - Sketchy Group LLC

Last Updated: September 21, 2021

Sketchy Group LLC (“Sketchy”) provides, among other things, materials designed to make learning unforgettable This Privacy Policy (“Privacy Policy” or “Policy”) explains our practices regarding the collection, use, and disclosure of information that we receive through our our website located at www.sketchy.com (the “Site”) and our communications with you (collectively, the “Services”). It also serves as a way to help you understand and exercise your privacy rights. This Privacy Policy does not apply to any third-party websites, services, or applications, even if they are accessible through our Services

Revisions to this Privacy Policy

Any information that is collected via our Services is covered by the Privacy Policy in effect at the time such information is collected. We may revise this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we’ll notify you of those changes by posting them within the Services or by sending you an email or other notification, and we’ll update the “Last Updated” date above to indicate when those changes become effective.

Scope of the Privacy Policy

This Privacy Policy applies to all users of our Services including without limitation, site visitors, account holders, registered users, and enterprise customers (all such users of the Services collectively referred to as “Users”). This Privacy Policy does not apply to any of the information that our customers may collect and process while using our Services (“Customer Data”). Our customers’ respective privacy policies govern their collection and use of Customer Data. Our processing of Customer Data is governed by the contracts that we have in place with our customers, not this Privacy Policy. 

Information That We Collect

This section describes the different types of Personal Data we may obtain about you.

Information that You Provide Directly
  • Sign Up Information: When you sign up to create an account, we collect and retain certain information about or which could be used to identify you (“Personal Data”), including, in the case of account creation: your first name, last name, phone number, email address, school or academic institution, and class year. If you create an account through a third party sign-on service (for example, Sign Up with Google), that service will inform you what information will be shared and should request your consent.
  • Through Communicating with Us: You may provide information to us when you use the Services, including when you contact support, inquire about your subscription, respond to surveys, or provide feedback about the Services. This information may include your name, email address, phone number, address, order payment information, and other information that may relate to you or identify you. We also collect any information you provide to us when you send us emails with queries, feedback, or for any other reason. 
  • Purchase and Payment Information: When you purchase a subscription or products, whether through the Site or by other means, we will keep records of what you purchased or ordered, and will ask you to provide financial information such as payment method or credit card information so we can charge you for the subscription or products. Because we use a payment processor for transactions made through the Site, we do not directly collect or store the payment card information entered through the payment portion of the Site. Such information is provided directly to our third-party processor, whose use of your personal information is governed by their privacy policy.
  • Through Interactive Features: If you use any of our interactive features, such as messaging between Users, comment features, or social features, we will collect information that you might submit or make available. Information that you provide through public sharing features of the Services will be considered public, except where contrary to applicable law.
  • Contact Information of Others: If you choose to share contact information of other individuals with us, for example if you are using a referral feature or a friend finder feature, we will collect and retain the contact information that you provide. Please only share the contact information of close friends and relations to you, or of others who have consented to such sharing of their information.
  • Job Applications: We may post job openings and opportunities on our Services. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and use your information to assess your qualifications.
Information Collected Automatically
  • Information Sent by Your Device: We collect certain information that your mobile device, laptop, or other hardware device sends when you use our Services, including but not limited to IP Address, user agent information, network and connectivity information, device identifiers, advertising identifiers, language preferences, user settings, software and operating system names and versions, hardware models, as well as other information about your use of our Services.
  • Location Information: When you use our Services, we may collect and store information about your location by converting your IP address into a rough geo-location, or by requesting precise location through your browser settings.
  • Information Collected Using Cookies and other Web Technologies: Like many website owners and operators, we (and our partners who assist us with marketing, analytics, User research, advertising, and user support) may utilize automated data collection tools such as cookies, web beacons, and pixel tags to collect certain information from Users of our Services. These tools are used for a variety of purposes, including but not limited to User authentication, account security, delivery and measuring of advertising, analyzing site traffic and trends, and fraud prevention. Cookies are small text files that are placed on your device by a web server when you access our Services. We may use both session cookies and persistent cookies to identify that you’ve logged in to the Services and to tell us how and when you interact with our Services. You have choices related to whether you want to accept (see the Your Choices section below). Please note, however, that if you don’t accept cookies, you may not be able to access all portions or features of the Services. Web beacons (also known as web bugs, pixel tags, or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on the device, Web Beacons are typically embedded invisibly on web pages (or in an email).  Note when we used the defined term “Cookies” in this Privacy Policy, we are referring collectively to cookies, pixel tags, beacons, and similar tracking technologies. Our use of Cookies falls into the following general categories:
  • Necessary Cookies: We use this type of Cookie to run our site, and to identify and prevent security risks. For instance, we may use these cookies to store your session information to prevent others from changing your password without your username and password.
  • Performance Cookies: We use this type of Cookie to collect information about how you use our site, monitor site performance, and improve our site performance, our services, and your experience. For example, we can use these Cookies to learn more about which features are the most popular with our Users and which ones might need some tweaks.
  • Preference Cookies: We use this type of Cookie to remember your settings and preferences, and to improve your experience on our site.  For instance, we may use these Cookies to remember your language preferences.
  • Marketing Cookies: We use this type of Cookie to deliver advertisements, to make them more relevant and meaningful to consumers, and to track the efficiency of our advertising campaigns, both on our services and on other sites or mobile apps. 
  • Interaction Data: We also collect information relating to the actions that you perform while logged into your account, such as page views, time spent on certain content and features, and buttons clicked.
How We Use the Information

Our primary goals in collecting information are to provide and improve our Services, to customize content and the Services for you, to administer your use of the Services (including your account, if you are an account holder), and to enable you to enjoy and easily navigate our Services. We will use your Personal Data for the following purposes:

  • Providing our Services, including all of the learning materials we make available, communicating with you, and providing customer support in relation to the Services;
  • Resolving disputes, responding to inquiries, collecting and processing payments fees (as applicable) and troubleshooting problems;
  • Collecting and processing payment;
  • Managing our everyday business needs, including, but not limited to the following activities: auditing, administration of the Services, forum management, fulfillment, analytics, fraud prevention, identify verification, and enforcement of our Terms of Service, or to comply with applicable laws or regulations;
  • Customizing your experience and otherwise measuring and improving our content and Services;
  • Sending you relevant emails and communications (including keeping you informed about our products, offerings, and any promotional offers) that might be of interest to you.  (In the event that we use your Personal Data to market to you, you will be able to opt-out of such uses);
  • Enforcing our agreements, terms, conditions, and policies, and sending you notices and alerts;
  • Better understanding our Users’ interests, behaviors, and demographics;
  • Short-term, transient use, such as contextual customization of ads;
  • Auditing relating to interactions, transactions and other compliance activities, and;
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity.

We may use Personal Data and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services.

We may also use your information for any other purpose disclosed to you at the time we collect or receive your information, or otherwise with your consent. Any communication or material you transmit to us via e-mail or otherwise, including any data, questions, comments, chats, phone calls, suggestions or the like (though excluding your Personal Data) will be treated as non-confidential and non-proprietary.

Information that We Share with Third Parties

We may share information you provide us, including your Personal Data, with third parties, in the types of scenarios, and for the types of reasons described in this section.

  • Services Providers and Business Partners: We may engage third-party service providers to help us administer, provide, and improve the Services, including but not limited to the following types of partners: third party financial financial institutions and financial services companies, web hosting providers, cloud hosting providers, fraud detection services, identity verification services, fulfillment service providers, and customer support partners. These third-party services providers will have access to your Personal Data for the purpose of performing services on our behalf. For example, we may share your Personal Data with a cloud hosting provider (for example, Amazon Web Services) as part of our utilization of their hosting services.
  • At Your Request: We may share information about you with third parties in the event that you request we do so, for example, with other Users or groups of Users or the public if you request that or if, for instance, you use a feature that performs that type sharing function. Similarly we may share information about you with companies offering complimentary services, promotions, or offers if you request, or consent, that we share your information.
  • The General Public: We may share with the general public information that you submit in public forums, for example blogs, social media, comment sections on the website.
  • Other Third Parties: We may share de-identified or aggregated data we collect from the use of the Services, including but not limited to de-identified or aggregated transaction or investment  information, de-identified or aggregated location information, information about the computer or device from which you access the Services, market trends, and other analysis that we create based on the information we receive from you and other Users.
  • Our Subsidiaries and Affiliates: We share information with our corporate subsidiaries and affiliates, including parent and holding companies, for our administrative purposes, including activities such as IT management, auditing and compliance, and for them to provide services to you or support and supplement the Services we provide. Note that Sketchy Medical recently closed a majority-stake investment from an affiliate of TCG Capital Management ("TCG"). In connection with the investment, Sketchy Medical has undergone a corporate restructuring whereby Sketchy Group LLC is a now a wholly owned subsidiary of newly-created holding company ("Sketchy Parent"). Pursuant to our Privacy Policy, we are notifying you that your information may be transferred to Sketchy Parent, who will only use it in accordance with the terms of our Privacy Policy.
  • With Your Consent: There may be other circumstances where we will notify you of information that we seek to share with a third party not listed here, and will do so with your consent.
  • Information Shared with Web Analytics Services Providers: As of the effective date of this Privacy Policy, we use the following analytics services. If we add new analytics providers in the future, they will be included in the next version of the privacy policy.
  • Google: We use Google Analytics, a service provided by Google, Inc. (“Google”), to gather information about how Users engage with our Site and Services. For more information about Google Analytics, please visit this page. You can opt out of Google’s collection and processing of data generated by your use of the Services by going here.
  • Hubspot: We use a service provided by Hubspot, Inc. (“Hubspot”) to provide us with analytics data regarding Users’ interactions with our Site and Services. You can learn how to opt-out of Hubspot’s automatic retention of data that is collected while using the Services by visiting this page. To track opt-outs, Hubspot uses a persistent opt-out cookie placed on your device. Please note that if you get a new computer, install a new browser, erase or otherwise alter the browser’s cookie file (including upgrading certain browsers), you may delete the Hubspot opt-out cookie.
  • Heap: We use a service provided by Heap, Inc. (“Heap”) to provide us with analytics data regarding Users’ interactions with our Site and Services. You can learn about Heap’s cookie practices, policies, and cookie choices by visiting this page. To track opt-outs, Heap uses a persistent opt-out cookie placed on your device. Please note that if you get a new computer, install a new browser, erase or otherwise alter the browser’s cookie file (including upgrading certain browsers), you may delete the Heap opt-out cookie.
  • Information Disclosed in Connection with Business Transactions: Information that we collect from our Users, including Personal Data, is considered to be a business asset. Thus, if we are acquired by a third party as a result of a transaction such as a merger, acquisition, or asset sale, or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your Personal Data, may be disclosed or transferred to a third party acquirer in connection with the transaction.
  • Information Disclosed for Our Protection and the Protection of Others: We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims, legal process (including subpoenas); (ii) to protect our property, rights and safety and the property, rights and safety of a third party or the public in general; and (iii) to stop any activity that we consider illegal, unethical or legally actionable activity.
  • With Advertising Partners and Social Media. Your Personal Data may be shared with certain advertising partners who conduct or assist us with marketing, as well as advertising and social media partners who we allow to place cookies (or similar technology) in our Services as necessary to their provision of various services, including but not limited to ad attribution, ad placement, audience measurement, social sharing, and site analytics.
  • Google: We use a service provided by Google called Google AdWords which provides Sketchy the ability to remarket to users who have visited sketchy.com. Third-party vendors, including Google, show our ads on various sites across the Internet and use cookies to serve you ads based on your past visits to this Site. You can opt out of Google's use of cookies by visiting Google's Ads Settings (https://www.google.com/settings/ads/plugin). Alternatively, you can opt out of a third-party vendor's use of cookies by visiting the Network Advertising Initiative opt-out page (http://www.networkadvertising.org/choices/).
  • Facebook: We use a service provided by Facebook called Facebook Ads Manager which provides Sketchy with pixel tags from Facebook. The information collected is used to help us display placed advertisements only to users that have shown a clear interest in our services or have certain characteristics that have been transferred to Facebook. By using the Facebook-Pixel we can trace whether a user has clicked on a Facebook-Ad and has thereby been redirected to our website.
Your Privacy Rights

Based upon the laws that apply in your jurisdiction, you may have some or all of the following rights, related to your privacy and Personal Data. Please note that for each of the rights below we may have valid legal reasons to refuse your request. In such instances we will let you know if that is the case. To inquire about or to exercise any of these rights, you may contact us a privacy@sketchy.com. We will process such requests in accordance with applicable laws.

  • Access: the right to access Personal Data about you, including: (i) confirming whether we are processing your Personal Data; (ii) obtaining access to or a copy of your Personal Data; and (iii) receiving an electronic copy of Personal Data that you have provided to us, or asking us to send that information to another company (the “right of data portability”);
  • Correction: the right to request correction of your Personal Data where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your Personal Data;
  • Deletion: the right to request deletion of your Personal Data;
  • Objection: the right to request restriction of or object to our processing of your Personal Data; and
  • Withdraw Consent: the right to withdraw your consent to our processing of your Personal Data.
Your Choices

We offer you choices regarding the collection, use and sharing of your Personal Data and we’ll respect the choices you make. Please note that if you decide not to provide us with the Personal Data that we request, you may not be able to access all of the features of the Services.

  • Opt-Out of our Emails: We may periodically send you free newsletters and emails that directly promote our Services. When you receive such promotional communications from us, you will have the opportunity to “opt-out” (by following the unsubscribe instructions provided in the email you receive). We do need to send you certain communications regarding the Services and you will not be able to opt out of those communications – e.g., communications regarding updates to our Terms of Service or this Privacy Policy or information about billing.
  • Cookie and Ad Tracking Choices: You can opt out of the collection and use of your information for ad targeting by going here or here to limit collection through the Site, by configuring the settings on your browser, by setting preferences in the cookie consent manager service on our site, or by using cookie blocking extensions in your browser (such as Privacy Badger or Ghostery). 
  • Modifying Your Information: You can access and modify the Personal Data associated with your account by sending an email to privacy@sketchy.com.  If you want us to delete your Personal Data or your account, please contact us at the same address (above) with your request. We’ll take steps to delete your information as soon as we can, but some information may remain in archived/backup copies for our records or as otherwise required by law.
  • Non-Affiliate Marketing: We do not currently share Personal Data with third parties seeking to market their own products or services to our Users, unless you indicate to us your consent for such sharing. However, in the event that the company would begin sharing such information for such a purpose, Users will be allowed to opt out of such sharing.
  • Additional Choices: As discussed below, additional choices may be available to you under Europe’s General Data Protection Regulation (see section below), California law, or Nevada law. You can learn about those choices in the specific privacy notices contained below in this Privacy Policy.
Responding to Do Not Track Signals 

Our Site does not currently have the capability to respond to “Do Not Track” signals received from various web browsers.

The Security of Your Information 

We take reasonable administrative, physical, and electronic measures designed to protect the information that we collect from or about you (including your Personal Data) from unauthorized access, use or disclosure. When you enter sensitive information on our forms, we encrypt this data using SSL or other technologies. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information. By using our Services or providing Personal Data to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.

Data Retention

We need to retain the information you provide us in order to provide our Services, and we retain such information for as long as you maintain your account, at a minimum. We also retain certain relevant information, including transaction, location, device, and usage information, for as long as it is required to do so, in connection with regulatory, tax, insurance, legal, administrative, and other requirements. You may request deletion of your account at any time as provided above. Following such a request, we will delete the information that it is not necessary to retain. In certain circumstances, we may be unable to delete your account, such as if there is an outstanding credit or debt on your account or an unresolved dispute, ongoing investigation (e.g. for fraud or misuse), or we believe that we may be required to retain your account for legal reasons. Upon resolution of the issue preventing deletion, we will delete your account as described above. We may also retain certain information if necessary for our legitimate business interests, such as fraud prevention and enhancing Users' safety and security. For example, if we shut down a User's account because of security or fraud incidents, we may retain certain information about that account to prevent that User from opening a new account in the future.

Links to Other Sites

Our Services may contain links to websites and services that are owned or operated by third parties (each, a “Third-party Service”). Any information that you provide on or to a Third-party Service or that is collected by a Third-party Service is provided directly to the owner or operator of the Third-party Service and is subject to the owner’s or operator’s privacy policy. We’re not responsible for the content, privacy, or security practices and policies of any Third-party Service. To protect your information we recommend that you carefully review the privacy policies of all Third-party Services that you access.

Cross Border Transfer 

Your Personal Data may be transferred to, and maintained on, computers located outside of your state, province, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. We strive to safeguard your information consistent with the requirements of applicable laws.

Our Policy Toward Children 

Our Services are not directed to children under 13, and we do not knowingly collect Personal Data from children under 13. If we learn that we have collected Personal Data of a child under 13, we will take steps to delete such information from our files as soon as possible.

Privacy Notice for Nevada Residents

Nevada residents have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at privacy@sketchy.com and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined under Nevada law.

Privacy Notice for California Residents

If you’re a California resident, you have certain privacy rights under California law, including the California Consumer Privacy Act of 2018 (“CCPA”), the California Shine the Light Law, and the California Eraser Law (or Right to Be Forgotten). Those rights are all discussed in this Privacy Notice for California Residents section of our broader Privacy Policy.

  California Consumer Protection Act

    Your Rights Under the California Consumer Protection Act
    
The following rights (in this section) are available  to California residents.

  • Right to request disclosure of information shared or sold. First, we do not sell your Personal Data (or “personal information,” as used in the CCPA) within the meaning of the CCPA. That said, we do share certain data about some of our Users with service providers. This sharing is outlined in this broader Privacy Policy, as well as below. And you do have the right under CCPA to contact us at any time, as described in the section below, to request this information from us.   
  • Right to opt out of selling of your Personal Data. As stated above, we do not sell your Personal Data, within the meaning of the CCPA. That said, in the event that we ever do choose to sell data to third parties, we will provide a method to allow our Users to opt out of that selling, in accordance with California law.
  • Right to request deletion of data.  You have the right to request deletion of your data, unless an exception applies. Examples of exceptions include when we need to keep data to meet legal obligations, detect fraud, investigate reports of abuse or other Terms of Service violations, or fix security issues. Additionally, an exception would apply if we would be unable to provide the services that you signed up for without the data, in which case, you are free to request account deletion and cease use of the services. See more about this throughout the broader Privacy Policy. Once we’ve verified your request, we’ll delete your Personal Data (unless an exception applies) and will direct our service providers to do the same.
  • Timely response. You have the right to make two free requests in any 12-month period. We will respond to your request within 45 days, and in more difficult cases we may extend our response time by another 45 days.
  • Non-discrimination. We encourage our Users to think carefully about their privacy and data sharing habits. And in no way would we ever hold it against one of our Users should they choose to exercise the privacy rights granted them by the law. Don’t hesitate to reach out with questions or requests.
  • Right to request disclosure of information collected. You have the right to request details on the specific Personal Data we’ve collected about you. We provide detailed information about the types of information we collect throughout this broader Privacy Policy, but you may also contact us directly to inquire about your Personal Data specifically, as described in this Privacy Notice for California Residents section.

Contacting Us (CCPA Purpose)
To make any inquiries, request, or exercise any of your rights granted under California Consumer Protection Act, you can contact us by email at privacy@sketchy.com. Please state that you are a California resident in that communication. We may need to go through a few verification steps after you reach out, but we’ll help you through that.

Information We Collect (CCPA Required Disclosure)
As we address throughout this Privacy Policy, we collect Personal Data for a range of purposes, though primarily to allow us to provide and improve our services. In the last twelve months, we have collected the following categories of Personal Data about our Users. In some cases the data is provided directly by Users. In other cases it was provided by third parties, or obtained through User interaction with our services.

  • Identifiers, such as your name, email address, IP address, username, or other similar identifiers. We primarily use these identifiers to create your account, maintain security of our services, and communicate with you. 
  • Customer records information, such as telephone number, bank account number, credit card number, or debit card number. We primarily use these types of information to facilitate transactions and payments. (This category under CCPA overlaps with other categories.)
  • Commercial information, such as payment history and purchase history. We primarily use this type of information to keep track of user transactions and for internal business and financial recordkeeping.
  • Internet or other electronic network activity information, such as session logs, search history, information about your interaction with a website, application, or advertisement. We primarily use this type of information to help us understand how our services are and advertisements are performing.
  • Geolocation information, such as your IP address which provides a rough approximation of location. We use this data primarily to understand where our site visitors are accessing the services, and in some cases to provide more relevant advertising.  
  • Education Information, such as the school you attend and your year in school.

Information Sharing (CCPA Disclosure)
In the past 12 months, we’ve disclosed the above categories of information for business purposes, or at your direction, with our service providers, affiliates, and other third-parties. For instance, we share Personal Data about our Users with our data hosting and storage providers. We have agreements with our service providers which limit their ability to use your information and require them to ensure its confidentiality.

Updates to this CCPA Section of the Privacy Notice for California Residents
We will update this Notice every 12 months and let you know when we’ve made updates, consistent with our Privacy Policy.


California Shine the Light Law
The California “Shine the Light” law permits Users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Data (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Data disclosed to those parties. Please note, we do not currently share Personal Data with third parties seeking to market their own products or services to our Users, unless you have indicated to us your consent for such sharing.

California Right to be Forgotten
Where required by law, California residents under the age of 18 may request to have their posted content or information removed from the publicly-viewable portions of our Services by contacting us directly at privacy@sketchy.com.

Privacy Notice for Users in the European Union

If you are a User in the European Union, you should know that Sketchy Group LLC is the controller of your Personal Data. And we encourage you to review the remainder of this section to understand the bases upon which we process Personal Data as well as the rights afforded to you under the European Union’s General Data Protection Regulation 2016/679 (“GDPR”).

    Bases for Processing of Personal Data 

    Pursuant to the GDPR, we may process Personal Data under only the following conditions:

  • Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
  • Performance of a Contract: provision of Personal Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
  • Legal Obligations: processing Personal Data is necessary for compliance with a legal obligation to which we are subject.
  • Vital Interests: processing Personal Data is necessary in order to protect your vital interests or of another natural person.
  • Public Interest: processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the company.
  • Legitimate Interests: processing Personal Data is necessary for the purposes of the legitimate interests pursued by the company.

We will gladly help to clarify the specific legal basis that applies to any processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Rights Under the GDPR 

Where the European Union’s General Data Protection Regulation 2016/679  (“GDPR”) applies, in certain circumstances and subject to data processing agreements, you have rights in relation to the Personal Data we hold about you. We set out below an outline of those rights and how to exercise those rights. Please note that we will require you to verify your identity before responding to any requests to exercise your rights by providing details only known to the account holder. Please note that for each of the rights below we may have valid legal reasons to refuse your request. In such instances we will let you know if that is the case. To inquire about or to exercise any of these rights, you may contact us at privacy@sketchy.com.

  • Access: You have the right to know whether we process Personal Data about you, and if we do, to access data we hold about you and certain information about how we use it and who we share it with.
  • Portability: You have the right to receive a subset of the Personal Data you provide us if we process it on the legal bases of our contract with you or with your consent in a structured, commonly used and machine-readable format and a right to request that we transfer such Personal Data to another party. If you wish for us to transfer the Personal Data to another party, please ensure you detail that party and note that we can only do so where it is technically feasible. We are not responsible for the security of the Personal Data or its processing once received by the third party.
  • Correction: You have the right to require us to correct any Personal Data held about you that is inaccurate and have incomplete data completed. When you request correction, please explain in detail why you believe the Personal Data we hold about you to be inaccurate or incomplete so that we can assess whether a correction is required. Please note that while we assess whether the Personal Data we hold about you is inaccurate or incomplete, you may exercise your right to restrict our processing of the applicable data as described below.
  • Erasure: You may request that we erase the Personal Data we hold about you in the following circumstances: where you believe it is no longer necessary for us to hold the Personal Data; we are processing it on the basis of your consent and you wish to withdraw your consent; we are processing your data on the basis of our legitimate interest and you object to such processing; you no longer wish us to use your data to send you marketing; or you believe we are unlawfully processing your data. Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure. Please know there may be some types of Personal Data that we are required to retain for legal, regulatory, or accounting reasons, or other legitimate interests.
  • Restriction of Processing to Storage Only: You have a right to require us to stop processing the Personal Data we hold about you other than for storage purposes in the following circumstances: you believe the Personal Data is not accurate for the period it takes for us to verify whether the data is accurate; we wish to erase the Personal Data as the processing we are doing is potentially unlawful but you want us to simply restrict the use of that data; we no longer need the Personal Data for the purposes of the processing but you require us to retain the data for the establishment, exercise or defense of legal claims; or you have objected to us processing Personal Data we hold about you on the basis of our legitimate interest and you wish us to stop processing the Personal Data while we determine whether there is an overriding interest in us retaining such Personal Data.
  • Objection: You have the right to object to our processing of data about you and we will consider your request. Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims. You also have the right, at any time, to object to our processing of data about you in order to send you marketing, including where we build profiles for such purposes and we will stop processing the data for that purpose.
  • Withdrawal of Consent: Where you have provided your consent to us processing your Personal Data, you can withdraw your consent at any time by emailing us at the address above in this section.
California Consumer Protection Act

If you’re based in the EU, you are able to file a complaint with the supervisory authority in your Member State. That said, we’d encourage you to reach out to us directly first (at privacy@sketchy.com) so we can try to assist you with your questions or help you exercise the rights you’re seeking to exercise. Please note that EU consumers and regulators also have the option of contacting us through our appointed GDPR representative  at the following address: Osano International Compliance Services Limited, ATTN: 3EVV, 25/28 North Wall Quay, Dublin 1, D01 H104, Ireland

Privacy Questions and Requests

We know issues of privacy and data protection are complex. But we’re here to help in any way we can. So please contact us, via email (below) if you have any questions about your Personal Data, our data practices, or this Privacy Policy. 

Sketchy Group LLC
2372 Veteran Avenue
Los Angeles, CA 90064
privacy@sketchy.com

Privacy Policy - Sketchy Group LLC

Last Updated: September 17, 2021

Sketchy Group LLC (“Sketchy”) provides, among other things, materials designed to make learning unforgettable This Privacy Policy (“Privacy Policy” or “Policy”) explains our practices regarding the collection, use, and disclosure of information that we receive through our our website located at www.sketchy.com (the “Site”) and our communications with you (collectively, the “Services”). It also serves as a way to help you understand and exercise your privacy rights. This Privacy Policy does not apply to any third-party websites, services, or applications, even if they are accessible through our Services

Revisions to this Privacy Policy

Any information that is collected via our Services is covered by the Privacy Policy in effect at the time such information is collected. We may revise this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we’ll notify you of those changes by posting them within the Services or by sending you an email or other notification, and we’ll update the “Last Updated” date above to indicate when those changes become effective.

Scope of the Privacy Policy

This Privacy Policy applies to all users of our Services including without limitation, site visitors, account holders, registered users, and enterprise customers (all such users of the Services collectively referred to as “Users”). This Privacy Policy does not apply to any of the information that our customers may collect and process while using our Services (“Customer Data”). Our customers’ respective privacy policies govern their collection and use of Customer Data. Our processing of Customer Data is governed by the contracts that we have in place with our customers, not this Privacy Policy. 

Information That We Collect

This section describes the different types of Personal Data we may obtain about you.

Information that You Provide Directly
Information Collected Automatically

Information From Third PartiesWe may also obtain information about Users from third parties, including but not limited to affiliates, joint marketing partners, lead providers, fraud and risk mitigation vendors, and identify verification services.

How We Use the Information 

Our primary goals in collecting information are to provide and improve our Services, to customize content and the Services for you, to administer your use of the Services (including your account, if you are an account holder), and to enable you to enjoy and easily navigate our Services. We will use your Personal Data for the following purposes:

We may use Personal Data and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services.

We may also use your information for any other purpose disclosed to you at the time we collect or receive your information, or otherwise with your consent. Any communication or material you transmit to us via e-mail or otherwise, including any data, questions, comments, chats, phone calls, suggestions or the like (though excluding your Personal Data) will be treated as non-confidential and non-proprietary. 

Information that We Share with Third Parties

We may share information you provide us, including your Personal Data, with third parties, in the types of scenarios, and for the types of reasons described in this section.

Your Privacy Rights

Based upon the laws that apply in your jurisdiction, you may have some or all of the following rights, related to your privacy and Personal Data. Please note that for each of the rights below we may have valid legal reasons to refuse your request. In such instances we will let you know if that is the case. To inquire about or to exercise any of these rights, you may contact us a privacy@sketchy.com. We will process such requests in accordance with applicable laws.

Your Choices

We offer you choices regarding the collection, use and sharing of your Personal Data and we’ll respect the choices you make. Please note that if you decide not to provide us with the Personal Data that we request, you may not be able to access all of the features of the Services.

Responding to Do Not Track Signals 

Our Site does not currently have the capability to respond to “Do Not Track” signals received from various web browsers.

The Security of Your Information 

We take reasonable administrative, physical, and electronic measures designed to protect the information that we collect from or about you (including your Personal Data) from unauthorized access, use or disclosure. When you enter sensitive information on our forms, we encrypt this data using SSL or other technologies. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information. By using our Services or providing Personal Data to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.

Data Retention

We need to retain the information you provide us in order to provide our Services, and we retain such information for as long as you maintain your account, at a minimum. We also retain certain relevant information, including transaction, location, device, and usage information, for as long as it is required to do so, in connection with regulatory, tax, insurance, legal, administrative, and other requirements. You may request deletion of your account at any time as provided above. Following such a request, we will delete the information that it is not necessary to retain. In certain circumstances, we may be unable to delete your account, such as if there is an outstanding credit or debt on your account or an unresolved dispute, ongoing investigation (e.g. for fraud or misuse), or we believe that we may be required to retain your account for legal reasons. Upon resolution of the issue preventing deletion, we will delete your account as described above. We may also retain certain information if necessary for our legitimate business interests, such as fraud prevention and enhancing Users' safety and security. For example, if we shut down a User's account because of security or fraud incidents, we may retain certain information about that account to prevent that User from opening a new account in the future.

Links to Other Sites

Our Services may contain links to websites and services that are owned or operated by third parties (each, a “Third-party Service”). Any information that you provide on or to a Third-party Service or that is collected by a Third-party Service is provided directly to the owner or operator of the Third-party Service and is subject to the owner’s or operator’s privacy policy. We’re not responsible for the content, privacy, or security practices and policies of any Third-party Service. To protect your information we recommend that you carefully review the privacy policies of all Third-party Services that you access.

Cross Border Transfer 

Your Personal Data may be transferred to, and maintained on, computers located outside of your state, province, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. We strive to safeguard your information consistent with the requirements of applicable laws.

Our Policy Toward Children 

Our Services are not directed to children under 13, and we do not knowingly collect Personal Data from children under 13. If we learn that we have collected Personal Data of a child under 13, we will take steps to delete such information from our files as soon as possible.

Privacy Notice for Nevada Residents

Nevada residents have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at privacy@sketchy.com and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined under Nevada law.

Privacy Notice for California Residents

If you’re a California resident, you have certain privacy rights under California law, including the California Consumer Privacy Act of 2018 (“CCPA”), the California Shine the Light Law, and the California Eraser Law (or Right to Be Forgotten). Those rights are all discussed in this Privacy Notice for California Residents section of our broader Privacy Policy.

California Consumer Protection Act

Your Rights Under the California Consumer Protection Act
The following rights (in this section) are available  to California residents.

Contacting Us (CCPA Purpose)
To make any inquiries, request, or exercise any of your rights granted under California Consumer Protection Act, you can contact us by email at privacy@sketchy.com. Please state that you are a California resident in that communication. We may need to go through a few verification steps after you reach out, but we’ll help you through that.

Information We Collect (CCPA Required Disclosure)
As we address throughout this Privacy Policy, we collect Personal Data for a range of purposes, though primarily to allow us to provide and improve our services. In the last twelve months, we have collected the following categories of Personal Data about our Users. In some cases the data is provided directly by Users. In other cases it was provided by third parties, or obtained through User interaction with our services.

Information Sharing (CCPA Disclosure)
In the past 12 months, we’ve disclosed the above categories of information for business purposes, or at your direction, with our service providers, affiliates, and other third-parties. For instance, we share Personal Data about our Users with our data hosting and storage providers. We have agreements with our service providers which limit their ability to use your information and require them to ensure its confidentiality.

Updates to this CCPA Section of the Privacy Notice for California Residents
We will update this Notice every 12 months and let you know when we’ve made updates, consistent with our Privacy Policy.

California Shine the Light Law
The California “Shine the Light” law permits Users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Data (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Data disclosed to those parties. Please note, we do not currently share Personal Data with third parties seeking to market their own products or services to our Users, unless you have indicated to us your consent for such sharing.

California Right to be Forgotten
Where required by law, California residents under the age of 18 may request to have their posted content or information removed from the publicly-viewable portions of our Services by contacting us directly at privacy@sketchy.com.

Privacy Notice for Users in the European Union

If you are a User in the European Union, you should know that Sketchy Group LLC is the controller of your Personal Data. And we encourage you to review the remainder of this section to understand the bases upon which we process Personal Data as well as the rights afforded to you under the European Union’s General Data Protection Regulation 2016/679 (“GDPR”).

Bases for Processing of Personal Data 

Pursuant to the GDPR, we may process Personal Data under only the following conditions:

We will gladly help to clarify the specific legal basis that applies to any processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Rights Under the GDPR 

Where the European Union’s General Data Protection Regulation 2016/679  (“GDPR”) applies, in certain circumstances and subject to data processing agreements, you have rights in relation to the Personal Data we hold about you. We set out below an outline of those rights and how to exercise those rights. Please note that we will require you to verify your identity before responding to any requests to exercise your rights by providing details only known to the account holder. Please note that for each of the rights below we may have valid legal reasons to refuse your request. In such instances we will let you know if that is the case. To inquire about or to exercise any of these rights, you may contact us at privacy@sketchy.com.

EU Questions and Complaints

If you’re based in the EU, you are able to file a complaint with the supervisory authority in your Member State. That said, we’d encourage you to reach out to us directly first (at privacy@sketchy.com) so we can try to assist you with your questions or help you exercise the rights you’re seeking to exercise. Please note that EU consumers and regulators also have the option of contacting us through our appointed GDPR representative  at the following address: Osano International Compliance Services Limited, ATTN: 3EVV, 25/28 North Wall Quay, Dublin 1, D01 H104, Ireland

Privacy Questions and Requests

We know issues of privacy and data protection are complex. But we’re here to help in any way we can. So please contact us, via email (below) if you have any questions about your Personal Data, our data practices, or this Privacy Policy. 

Sketchy Group LLC
2372 Veteran Avenue
Los Angeles, CA 90064
privacy@sketchy.com