Privacy Policy for www.pedrocohenfilm.com

Effective Date: June 19, 2024

This Privacy Policy describes the data protection practices of www.pedrocohenfilm.com (“Cohen Films,” “we,” “us,” or “our”). This Privacy Policy applies to information that we collect and use about you when you access or use the Pedro Cohen Film website, mobile application, or other online or mobile service that links to or otherwise presents this Privacy Policy to you. We refer to these products and services collectively as the “Services.”

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.

Information We Collect

We collect information about you through the means discussed below. Please note that we need certain types of information so that we can provide the Services to you. If you do not provide us with such information, or ask us to delete it, you may no longer be able to access or use our Services.

1. Information You Provide to Us

We collect a variety of information that you provide directly to us. For example, we collect information from you through:

– The Services you use or processing your orders

– Requests or questions you submit to us via online forms, email, or otherwise

– Your participation in sweepstakes, contests, or surveys

– Any reviews that you submit about the Services

– Account registration and administration of your account

– Uploads or posts to the Services

– Requests for customer support and technical assistance

Information about you

While parts of the Services may not require you to provide any information that can directly identify you by name (such as if you choose to browse the website without logging in), the specific types of information we collect will depend upon the Services you use, how you use them, and the information you choose to provide. The types of data we may collect directly from you include the following:

– Email address

– Name, if you choose to provide it

– Log-in credentials, if you create a Cohen Films account

– Billing information, such as shipping address of a gift card recipient, credit or debit card number, verification number, zip code, and expiration date

– Phone number, if you choose to provide it

– Information about purchases or other transactions with us

– Information about your customer service interactions with us

– Demographic information such as your gender or other information you choose to provide as part of your Cohen Films profile

– User-generated content you provide to us, such as when you comment on content on the Services, respond to a survey request, participate in a class, review a class, produce material in/for the classes, or participate in the public forums

– Classes in which you enroll

– Any other information you choose to directly provide to us in connection with your use of the Services

Information about others

If you request that your purchase be provided to someone other than yourself (such as a gift recipient), we use the information you provide about the other person to fulfill the shipment.

2. Information We Collect Through Automated Means

When you use our Services, we collect certain information as described in this Section. As discussed further below, we and our service providers (which are third-party companies that work on our behalf) may use a variety of technologies, including cookies and similar tools, to assist in collecting this information.

Websites

When you use our website, we collect and analyze information such as your IP address, browser types, browser language, operating system, software and hardware attributes (including device IDs), referring and exit pages and URLs, the number of clicks, pages viewed and the order of those pages, date and time of use, content watched, total minutes watched, error logs, and other similar information about how you use the website.

Mobile Applications

When you use a Cohen Films mobile application or software (“app”), we automatically receive certain information about the mobile phone, tablet, or computer used to access the app, including device identifiers, IP address, operating system, version, Internet service provider, browser type, domain name, and other similar information, whether and when you update the app, date and time of use, content watched, total minutes watched, error logs, and other similar information about how you use the app.

Location Information

When you use the Services, we and our service providers may automatically collect general location information (e.g., IP address, city/state, and/or postal code associated with an IP address, city/state) from your computer or mobile device.

3. Information We Collect from Social Media and Other Content Platforms

If you access the Services through a third-party connection or log-in (e.g., through a social network like Facebook or Twitter), you may allow us to have access to and store certain information from your social network profile. This can include your name, gender, profile picture, your “likes” and check-ins, and your list of friends, depending on your settings on such services. If you do not wish to have this information disclosed, do not use a social networking connection to access the Services. For a description of how social networking sites handle your information, please refer to their privacy policies and terms of use, which may permit you to modify your privacy settings. You may also have the option of posting your Services activities to Social Networking Services when you access content through the Services (for example, you may post to Facebook that you enrolled in a class on the Service); you acknowledge that if you choose to use this feature, your friends, followers, and subscribers on any Social Networking Services you have enabled will be able to view such activity.

4. Information We Collect from Others

We may receive additional information such as demographic and statistical information from third parties, such as business partners, marketers, researchers, analysts, and other parties that we may attribute to you based on your assignment to certain statistical groups. We use this information to supplement the information that we collect directly from you in order to derive your possible interests and to provide more relevant experiences for you and improve our products, analytics, and advertising.

How We Use Your Information

We, or our service providers, use your information for various purposes depending on the types of information we have collected from and about you, in order to:

– Provide the Services

– Complete a purchase or provide the Services you have requested, including invoicing and accounting

– Communicate with you and provide support

– Respond to your request for information and provide you with more effective and efficient customer service

– Provide you with updates and information about classes in which you have enrolled

– Marketing and content customization

– Contact you by email, postal mail, or phone regarding Cohen Films and third-party products, services, surveys, research studies, promotions, special events, and other subjects that we think may be of interest to you

– Customize the advertising and content you see on the Services

– Business operations

– Help us better understand your interests and needs, and improve the Services, including through research and reports, and test and create new products, features, and services

– Secure our websites and applications, and resolve app crashes and other issues being reported

– Legal purposes

– Comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others

– Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others

Combined Information

For the purposes discussed in this Privacy Policy, we may combine the information that we collect through the Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Policy.

Aggregate/De-identified Data

We may aggregate and/or de-identify any information collected through the Services so that such information can no longer reasonably be linked to you or your device. We may use such information for any purpose, including without limitation for research and marketing purposes, and may also disclose such data to any third parties, including advertisers, promotional partners, and sponsors.

Cookies and Similar Technologies

To collect the information in the “Information We Collect Through Automated Means” section above, we and our service providers use Internet server logs, local storage, cookies, tracking pixels, and other similar tracking technologies (collectively, “cookies”). We use these technologies in order to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences. Cookies are small text files that are placed on your computer or mobile device when you visit a site that enables us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Services you have visited; (iv) enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions.

As we adopt additional technologies, we may also gather information through other methods. Please note that you can change your settings to notify you when a cookie is being set or updated or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). Please note that by blocking, disabling, or managing any or all cookies, you may not have access to certain features or offerings of the Services. For more information about our use of cookies, please see our Cookie Policy.

Online Analytics and Advertising

1. Analytics

We may use third-party web analytics services (such as those of Google Analytics) on our Services to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by going to 

https://tools.google.com/dlpage/gaoptout

If you receive email from us, we may use certain analytics

 tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.

2. Online Advertising

The Services may integrate third-party advertising technologies that allow for the delivery of relevant content and advertising on the Services, as well as on other websites you visit and other applications you use. The ads may be based on various factors such as the content of the page you are visiting, information you enter such as your age and gender, your searches, demographic data, user-generated content, and other information we collect from you. These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored to your interests.

Third parties may also place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about you as discussed above, including your email address. These third parties (e.g., ad networks and ad servers such as Google, Meta, and others) may also serve tailored ads to you as you use the Internet and Internet-connected applications and access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services to assist in this activity.

We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your device you use to access the Services by such non-affiliated third parties. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the [Network Advertising Initiative’s Consumer Opt-Out link](https://optout.networkadvertising.org/), the [Digital Advertising Alliance’s Consumer Opt-Out link](https://optout.aboutads.info/), or [Your Online Choices](https://www.youronlinechoices.com/) to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for display advertising or customize Google display network ads, visit the [Google Ads Settings page](https://adssettings.google.com/). We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. For additional ways to opt out of targeted advertising activities under applicable law, see the “Your Rights and Choices” section below.

Please note that if you exercise the choices above, you will still see advertising when you use the Services, but it will not be tailored to you based on your online behavior over time.

3. Notice Concerning Do Not Track

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our website for third-party purposes, and that is why we provide the variety of opt-out mechanisms listed above. However, we do not currently recognize or respond to browser-initiated DNT signals. To learn more about Do Not Track, you can do so [here](https://allaboutdnt.com/). Please note that Do Not Track is a different privacy mechanism than the user “preference signal” referenced in the “Your Rights and Choices” section below, which is a browser-based control that indicates whether you would like to opt out of the processing of your information for certain purposes, such as the “sale” of your information or the disclosure of your information for targeted advertising purposes, under applicable laws.

How We Disclose Your Information

www.pedrocohenfilm.com  will disclose your information in the following ways:

Affiliates and Subsidiaries

We may disclose information we collect within the Cohen Films family of companies to deliver products and services to you, ensure a consistent level of service, and enhance our products, services, and your customer experience.

Service Providers

We provide access to or disclose your information to select third parties who perform services on our behalf. They have access to perform these services but are prohibited from using your information for other purposes. They provide a variety of services to us, including billing, sales, marketing, product content and features, advertising, analytics, research, customer service, data storage, security, fraud prevention, payment processing, and legal services.

Protection of Cohen Films and Others

By using the Services, you acknowledge and agree that we may access, retain, and disclose the information we collect and maintain about you if required to do so by law or in a good faith belief that such access, retention, or disclosure is reasonably necessary to: (a) comply with legal process (e.g., a subpoena or court order); (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property, or personal safety of Cohen Films, its agents and affiliates, its users, and/or the public. This includes exchanging information with other companies and organizations for fraud protection, spam/malware prevention, and similar purposes.

Business Transfers

As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions (including in contemplation of such transactions), user information may be among the transferred assets. If a portion or all of our assets are sold or transferred to a third party, customer information (including your email address) would likely be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable laws, we will comply with such restrictions.

Public Forums

Certain features of our Services make it possible for you to post comments publicly that other users can see. Any information that you submit through such features is not confidential, and we may use it for any purpose (including in testimonials or other marketing materials). Any information you post openly in these ways will be available to the public at large and potentially accessible through third-party search engines. Accordingly, please take care when using these features.

Aggregate/De-identified Information

From time to time, we may disclose aggregate and/or de-identified information about the use of the Services, such as by publishing a report on usage trends. The disclosure of such data is unrestricted.

Retention of Your Information

We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and used it and/or as required to comply with applicable laws.

How We Protect Your Information

Cohen Films takes technical and organizational security measures to protect the information provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error-free. Please keep this in mind when disclosing any information to Cohen Films via the Internet.

Mobile Services

The Service may include certain services that are available via a mobile device, including (i) the ability to upload content to the Service via a mobile device, (ii) the ability to browse the Service and the Site from a mobile device, and (iii) the ability to access certain features through an application downloaded and installed on a mobile device (collectively, the “Mobile Services”). To the extent you access the Service through a mobile device, your wireless service carrier’s standard charges, data rates, and other fees may apply. In addition, downloading, installing, or using certain Mobile Services may be prohibited or restricted by your carrier, and not all Mobile Services may work with all carriers or devices. In using the Mobile Services, you may provide your telephone number. By providing your telephone number, you consent to receive calls and/or SMS, MMS, or text messages at that number. We may disclose your phone numbers with our affiliates or with our service providers (such as customer support, billing or collections companies, and text message service providers) who we have contracted with to assist us in pursuing our rights or providing our Services under our Terms of Service, our policies, applicable law, or any other agreement we may have with you. You agree these parties may also contact you using autodialed or prerecorded calls and text messages, as authorized by us to carry out the purposes we have identified above, and not for their own purposes. In the event you change or deactivate your mobile telephone number, you agree to promptly update your Cohen Films account information to ensure that your messages are not sent to the person that acquires your old number.

Third-Party Links and Features

The Services contain links to third-party websites such as social media sites, and also contain third-party plug-ins (such as the Facebook “like” button and Twitter “follow” button). If you choose to use these sites or features, you may disclose your information not just to those third parties, but also to their users and the public more generally depending on how their services function. We are not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your information will be subject to the privacy policies of the third-party websites or services, and not this Privacy Policy. We urge you to read the privacy and security policies of these third parties.

Children’s Privacy

The Services are intended for general audiences and not for children under the age of 13. If we become aware that we have inadvertently collected “personal information” (as defined by the United States Children’s Online Privacy Protection Act) from children under the age of 13 without valid parental consent, we will take reasonable steps to delete it as soon as possible. We do not knowingly process data of EU residents under the age of 16 without parental consent. If we become aware that we have collected data from an EU resident under the age of 16 without parental consent, we will take reasonable steps to delete it as soon as possible. We also comply with other age

 restrictions and requirements in accordance with applicable local laws.

Your Rights and Choices

1. General Rights

Depending on your jurisdiction, you may have the right to make certain requests regarding your “personal information” or “personal data” (as such terms are defined under applicable law, and collectively referred to herein as “personal information”). Specifically, you may have the right to ask us to:

– Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we disclose personal information.

– Provide you access to and/or a copy of certain personal information we hold about you.

– Correct or update personal information we hold about you.

– Delete certain personal information we have about you.

– Object to or restrict the processing of your information.

– Revoke your consent for the processing of your information.

– Transfer your information to a third-party provider of services.

– Opt out of the processing of your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable.

You also have the right to opt out of “sales” of your information and “processing”/“sharing” of your information for targeted advertising purposes as described below in subsection 3.

As provided in applicable law, you also have the right to not be discriminated against for exercising your rights. Please note that certain information may be exempt from such requests under applicable law. For example, we need to retain certain information to provide our services to you. We also need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address. You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.

If you would like further information regarding your legal rights or would like to exercise any of them, please submit a privacy request here or email us at [email protected].

Depending on applicable law, you may have the right to appeal our decision to deny your request, if applicable. If we deny your request, we will provide you with information on how to appeal the decision, if applicable, in our communications with you.

2. Opting Out of Marketing Emails

You can unsubscribe from our marketing emails via the unsubscribe link provided in the emails. Please note that it may take us some time, consistent with our legal obligations, to process your request. Even if you opt out from receiving marketing messages from us, you will continue to receive administrative messages from us, such as order confirmations, updates to our policies and practices, or other communications regarding our relationship or transactions with you.

3. Notice of Right to Opt Out of Sales of Personal Information and Processing/Sharing of Personal Information for Targeted Advertising Purposes

As explained in the “Online Analytics and Advertising” section above, we provide certain information to third-party advertising providers for targeted advertising purposes, so that we can provide you with more relevant and tailored ads regarding our services, and use analytics partners to assist us in analyzing the use of our services and our user/customer base. The disclosure of your information to these third parties to assist us in providing these services may be considered a “sale” of personal information under applicable law, or the “processing”/”sharing” of your information for targeted advertising purposes.

If you would like to opt out of our online disclosure such as through cookie and pixel technology of your information for purposes that could be considered “sales” for those third parties’ own commercial purposes, or “sharing” for purposes of targeted advertising, please click [here](https://optout.networkadvertising.org/). You can also submit a sale opt-out request to opt out of our offline disclosures of information that are subject to applicable opt-out rights by emailing us at [email protected]. Please note that we do not knowingly sell the personal information of minors under 16 years of age without legally-required affirmative authorization.

Please note that if you have a legally-recognized browser-based opt-out preference signal turned on via your device browser, we recognize such preference in accordance with applicable law.

Legal Bases for Use of Your Information

The legal bases for using your information as set out in this Privacy Policy are as follows:

– Where use of your information is necessary to perform our obligations under a contract with you (for example, to comply with the terms of service of our websites which you accept by browsing the websites/registering; and/or our contract to provide our Services to you);

– Where use of your information is necessary for our legitimate interests or the legitimate interests of others (for example, to provide security for our website and applications; operate our business and our Services; make and receive payments; comply with legal requirements and defend our legal rights; prevent fraud and to know the customer to whom we are providing Services);

– Where we are required to process information in accordance with an EU Member State legal obligation; or

– Where we have your consent, in accordance with applicable law.

International Transfer and Data Privacy Framework

The information discussed in this Policy is processed in the United States by Cohen Films, whose principal office in the United States is located at 15475 Willow Arbor Cir, Orlando, FL 32824

Cohen Films complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Cohen Films has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Cohen Films has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit [https://www.dataprivacyframework.gov/](https://www.dataprivacyframework.gov/).

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF Principles, Cohen Films commits to resolving complaints about your privacy and our collection or use of your personal data. European Union, United Kingdom, or Swiss citizens with inquiries or complaints regarding this privacy policy should first contact Cohen Films at [email protected]. Cohen Films has further committed to refer unresolved privacy complaints under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF Principles to an independent dispute resolution mechanism. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Cohen Films, please visit the [JAMS EU Privacy Shield website](https://www.jamsadr.com/dpf-dispute-resolution) for more information and to file a complaint. Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a DPF Panel. Cohen Films is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) with respect to its compliance with the provisions of the EU-US and Swiss-US Privacy Shield.

If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. As described above, we also may subcontract the processing of your data to, or otherwise disclose your data to, other members within the Cohen Films group of companies, service providers, and business partners in countries other than your country of residence, including the United States, in accordance with applicable law. Such third parties may be engaged in, among other things, the provision of Services to you, the processing of transactions, and/or the provision of support services. By providing us with your information, you acknowledge any such transfer, storage, or use. Cohen Films will take reasonable and appropriate steps necessary to ensure that any third party who is acting as a “data processor” under EU and Swiss terminology is processing the personal data we entrust to them in a manner that is consistent with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF Principles. Cohen Films is potentially liable in cases of onward transfer to third parties of data of EU, UK, and Swiss individuals received pursuant to the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF, respectively.

If applicable, you may make a complaint to the data protection supervisory authority in the country where you reside. Alternatively, you may seek a remedy through local courts if you believe your rights have been breached.

Changes to Our Privacy Policy

We reserve the right to amend this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. We will make the revised Privacy Policy accessible through the Services, so you should review the Privacy Policy periodically. You can know if the Privacy Policy has changed since the last time you reviewed it by checking the “Date of Last Revision” included at the beginning of the document. If we make a material change to the Policy, you will be provided with appropriate notice in accordance with legal requirements. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Privacy Policy.

This policy outlines how Pedro Cohen Films LLC handles your data to ensure transparency and protect your privacy while you engage with our services. If you have any questions or concerns, please contact us at [email protected].