Privacy Policy

This Privacy Policy was last updated on June 20, 2020

Bnei Baruch America, Inc. (“Bnei Baruch America” “we”, “us” or “our” in this privacy policy) is a noncommercial, public benefit, charitable and educational, nonprofit incorporated in the state of Missouri, United States, and is described as a public charity under section 501(c)(3) of the United States Internal Revenue Code, Bnei Baruch America respects your privacy as a visitor to its website and has developed the following privacy policy to inform you about how Bnei Baruch America handles your personal information after receiving it. This Privacy Policy governs Bnei Baruch America’s use of your information on the Bnei Baruch America “KabU” website (https://kabuconnect.com/) and includes your use of the KabU materials, programs and KabU brand (collectively, “Website”).

Please read this Online Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Policy. This Policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

1. Children Under the Age of 18

Our Website is not intended for children under 18 years of age without parent consent and supervision. No one under age 18 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 18. If you are under 18 do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent and supervision, we will delete that information. If you believe we might have any information from or about a child under 18 please contact us at set forth in paragraph 16 herein.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see California Privacy Rights Notice for more information.

2. The Services

Through its Website, Bnei Baruch America provides online teaching, training, classes, mentoring, courses, forums, interactive studies, videoconferencing, webinars, and other educational materials and services (collectively the “Services”) for the purpose of connecting interested individuals with the wisdom of Kabbalah, that is, the natural law of connection, the science of connection, and related subjects to explain what connects us to each other and to the reality around us.

3. Controller

Bnei Baruch America is the controller and responsible for your personal information.

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out in Section 16 below.

You have the right to make a complaint at any time to EU or other supervisory authorities for data protection issues (for EU see e.g., https://edps.europa.eu/data-protection/our-role-supervisor/complaints_en). We would, however, appreciate the chance to deal with your concerns before you approach such authorities so please contact us in the first instance.

4. Types of Information Collected and Stored

4.1. Personal Information Summary
When you engage in activities such to use Bnei Baruch America’s “KabU” branded services on our website, such as create a website user profile on our website, create an account, sign up to receive a publication, register to become a member, register for a class, course, or other educational materials, register for credentials or certification, register for a test, register for a conference or other event hosted by Bnei Baruch America, shop on our website, or otherwise use our website, Bnei Baruch America may gather your personally identifiable information (collectively “Personal Information”).

Your Personal Information may include, but is not limited to, your name, address, phone number, images, photograph, video and/or other graphic representations, your voice data, email address, birthdate, electronic signature, personal identification numbers, IP addresses, mobile device identifiers, geo-location, or any other personally identifying data collected from you by Bnei Baruch America or its authorized agents.

By using the Website and the Services, you agree to allow Bnei Baruch America and its agents to gather, store, and share your Personal Information subject to the limits of this Online Privacy Policy.

4.2. Specific types of data we collect about you. For the purpose of providing the Services and our legitimate business purposes, We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

4.2.1. Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

4.2.2. Contact Data includes billing address, delivery address, email address and telephone numbers.

4.2.3. Audio-Visual Data. When you participate in Bnei Baruch America programs, such as classes, courses, forums, interactive studies, ZOOMTM calls, video-conferences, webinars, and other interactive media, you may choose to provide to Bnei Baruch America digital audio visual information about you including images, photograph, videos and/or other graphic representations, and your voice data. Whether you provide such Audio-Visual Data is completely up to you, and your decision to not provide such Audio-Visual Data will not adversely affect your ability to use the Service.

4.2.4. Financial Data. When you use Bnei Baruch America website to shop for or to purchase Bnei Baruch America memberships, classes, courses, or other educational materials, register for Bnei Baruch America credentials or certification, register for a test, or purchase other materials, Bnei Baruch America utilizes third-party payment processors as its agents (“Payment Agents”) to process your payment and provide payment verification to Bnei Baruch America concerning your payment. Bnei Baruch America and its Payment Agents utilize systems whereby we substitute a proxy set of identifying information for your real financial information. Our Payment Agents, which do handle your credit cards and other payment information, are PCI Data Security Standard (“PCI DSS”) compliant. As a result, Bnei Baruch America does not collect or store your credit card numbers or other similar financially-related Personal Information and it isn’t exposed more than necessary. For more information about PCI DSS please visit https://www.pcisecuritystandards.org/about_us/.

4.2.5. Transaction Data includes details about payments to and from you and other details of Bnei Baruch America products and services you have purchased from us.

4.2.6. Technical Data includes internet protocol (IP) address, your Bnei Baruch America login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

4.2.7. Profile Data includes your Bnei Baruch America username and password, Bnei Baruch America purchases or orders made by you, your interests, preferences, feedback and survey responses.

4.2.8. Usage Data includes information about how you use the Bnei Baruch America website, products and services.

4.2.9. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

4.2.10. User Contributions. The Website may contain message boards, forums, IM’s or direct messaging, images, audio files, webinars, Zoom and other videoconferencing services, chat rooms, personal web pages or profiles, forums, bulletin boards, and other interactive features (collectively, “Interactive Services”) that allow You to post, submit, publish, display, or transmit to other users or other persons content, Your own image, video stream, voice data and materials on or through the Website. These types of data are collectively named “User Contributions” herein.

4.2.11 Aggregated Data / Analytics Information. We also collect, use and share Aggregated Data. In an effort to improve visitors’ experiences on the Bnei Baruch America website, Bnei Baruch America gathers this Aggregated Data related to individuals’ website visits. This information is used solely to measure and improve our website and services and to better serve our members and customers. Bnei Baruch America uses aggregate statistical data to compile reports. If we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy. This analytics information so gathered is likely to include the following:

4.2.11.1. Device and network specific information, such as your unique device identifier, operating system and version, the browser you use, your Internet service provider (ISP), and your IP address.

4.2.11.2. Non-personal information, such as language, zip code, area code, location, and the time zone.Aggregated Data / Analytics Information. We also collect, use and share Aggregated Data. In an effort to improve visitors’ experiences on the Bnei Baruch America website, Bnei Baruch America gathers this Aggregated Data related to individuals’ website visits. This information is used solely to measure and improve our website and services and to better serve our members and customers. Bnei Baruch America uses aggregate statistical data to compile reports. If we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy. This analytics information so gathered is likely to include the following:

4.2.11.3. Bnei Baruch America website visit information, such as the domain from which you came to our website or referring links, and details of how you use our website, including but not limited to what webpages you visit on the Bnei Baruch America website, as well as downloads, purchases, and orders during the duration of your visit. At times we will track user behavior over time during interactions with the site in order to pursue legitimate business interests, including, but not limited to, troubleshooting technical user issues with site services.

4.3. Sensitive Information
We do not collect the following Special Categories of personal data about you. Such Special Categories include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. Through your participation in the Services, you may, but need not, freely and voluntarily choose to post, share, provide contributions, or otherwise disclose Personal Information described within such Special Categories. Your sharing of Special Categories of personal data will not be requisite for your participation in the Services and We cannot guarantee the privacy of such disclosures described in this Section.

4.4. Cookies and Browser “Do Not Track” Notice

4.4.1. Bnei Baruch America may use cookies on your computer. A cookie is a small text file sent from a website and stored in a user’s web browser while the user is browsing that website. Every time the user loads the website, the browser sends the cookie back to the server to notify the website of the user’s previous activity. Bnei Baruch America does not, at present, permit third party advertisers on its Website. In the event that Bnei Baruch America chooses to permit third party advertisers, such third parties will not have access to Bnei Baruch America cookies, but they may use their own cookies on your computer. Advertisers’ use of their cookies and device identifiers is subject to the advertisers’ own privacy policies. Bnei Baruch America does not correlate its use of cookies with your Personal Information.

4.4.2. Bnei Baruch America does not respond to browser Do Not Track (“DNT”) Signals. Bnei Baruch America websites may utilize page tags or web beacons to track information related to user visits as a part of Bnei Baruch America data analytics processes and user experience customization as described below. Page tags are small pieces of Javascript embedded in webpages that collect data to help track web traffic on our website. Web beacons are very small, effectively invisible, graphic images we use to count and recognize users on our website. Such technologies enable us to improve and customize user experiences while users visit our website. Bnei Baruch America does not correlate its tracking activities through the use of page tags or web beacons with your Personal Information.

4.4.3. Bnei Baruch America may employ third party data analytics firms to track and analyze traffic on the Bnei Baruch America website, to analyze visitor trends, to determine advertising effectiveness, browser types and usage trends, and to present targeted ads based on anonymous information collected through tracking. These services also use cookies to accomplish such analytics-related services. Bnei Baruch America’ third party analytics firms, process the Personal Information they receive through the use of cookies in the aggregate.

4.4.4. Third parties that may advertise on Bnei Baruch America websites may have content embedded that sets cookies on a visitor’s browser and/or tracks visitor information that a web browser visited a specific Bnei Baruch America website. Such information may contain a visitor’s IP address. Third parties may not collect identifying Personal Information from the Bnei Baruch America website unless you provide it to such third parties.

4.4.5. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

4.5. Keeping Information Updated
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

5. Security of Personal Information

Bnei Baruch America takes the security of your Personal Information very seriously. When your Personal Information is stored by Bnei Baruch America, we use reasonable and appropriate measures to protect it from loss, misuse and unauthorized access, disclosure, alteration and destruction. Unfortunately, data transmission over public networks cannot be guaranteed to be one hundred percent secure. While Bnei Baruch America will use all reasonable means to protect your Personal Information, Bnei Baruch America cannot guarantee the security of your transmissions of such Personal Information, and you use the Bnei Baruch America website at your own risk. If you suspect your Personal Information has been compromised, please notify Bnei Baruch America Customer Service using the contact information provided below.

6. How we Collect Your Personal Information

We use different methods to collect data from and about you including through the following methods.

6.1. Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

6.1.1. apply for our Services;

6.1.2. create an account on our website;

6.1.3. subscribe to our Services or

6.1.4. receive our publications;

6.1.5. request marketing to be sent to you;

6.1.6. enter a competition, promotion or survey; or

6.1.7. give us feedback or contact us.

6.2. Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

6.3. Technical Data from the following parties:

6.3.1. analytics providers such as Google based outside the EU;

6.3.2. advertising networks based inside OR outside the EU; and

6.3.3. search information providers based inside OR outside the EU.

6.4. Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside OR outside the EU.

6.5. Identity and Contact Data from data brokers or aggregators based inside OR outside the EU.

6.6. Identity and Contact Data from publicly available sources.

7. How Bnei Baruch America Uses and Shares Your Information

7.1. General Information and Your Rights. Bnei Baruch America limits its use of your Personal Information to the stated purposes for which such information is collected. In some cases, Bnei Baruch America may be required to disclose your Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. You have the right to the following regarding your Personal Information transferred to Bnei Baruch America:

7.1.1. To know the types of Personal Information Bnei Baruch America collects;

7.1.2. To know the purposes for which it collects and uses your Personal Information;

7.1.3. To know type or identity of third parties to which Bnei Baruch America discloses your Personal Information, and the purposes for which it does so;

7.1.4. To access and update your Personal Information; and

7.1.5. To know the choices and means Bnei Baruch America offers you for limiting the use and disclosure of your Personal Information.

7.2. Bnei Baruch America Services to Bnei Baruch America Account Holders.
When you create an Bnei Baruch America account, we may use information collected from technologies such as cookies, web beacons, and page tags, as described herein, to improve your experience of our website. For example, by saving information concerning the pages you visit and products you purchase, we will be able to provide you with information on other Bnei Baruch America goods and services that may be of interest to you. Furthermore, by creating an account with Bnei Baruch America, there is a possibility of receiving content from third parties through Bnei Baruch America, as discussed under Section 5.6, below.

Based on the information we gather, we may use targeted advertising from third party vendors, customized to reflect your interests. For example, if you purchase certain materials from Bnei Baruch America, Bnei Baruch America may display advertisements from vendors of similar materials. To accomplish this, we may use cookies and other technologies in order to recognize your computer at the time we display an advertisement to you. Bnei Baruch America may tailor advertisements based on your use of our website, such as tracking the pages you visit, the searches you make, or the goods or services you purchase. Bnei Baruch America does not correlate activities described in this section with your Personal Information, and we will not provide advertisers with your Personal Information when you view a targeted advertisement. However, through your interaction with a targeted advertisement, you consent that an advertiser may infer that you meet certain targeting criteria for the display of the advertisement.

In creating an Bnei Baruch America Account, and as a condition of having an Bnei Baruch America Account and utilizing the Services, you must expressly consent to Bnei Baruch America’ collection and use of your Personal Information and non-personally identifiable information as described in this Online Privacy Policy. Moreover, in using a Bnei Baruch America Account and the Services you expressly acknowledge and agree to our collection and use of such information as described in this Online Privacy Policy.
You can opt-out of the use of your Personal Information as described in this Online Privacy Policy by deleting your Bnei Baruch America Account. To delete your Bnei Baruch America Account, please contact Bnei Baruch America Customer Service using the contact information provided below.

7.3. Other Bnei Baruch America Services.
Bnei Baruch America may use your Personal Information to provide services to you upon your request. Such services may include sending you newsletters and publications, responding to your questions and comments, communicating with you concerning your purchases on the Bnei Baruch America website, emailing you updates concerning Bnei Baruch America products and services, and personalizing your visits to Bnei Baruch America website.
You may opt-out of the use of your Personal Information as described in this Section by contacting Bnei Baruch America Customer Service using the contact information provided below.

7.4. Bnei Baruch America Internal Data Sharing
Bnei Baruch America may also share your Personal Information with other Bnei Baruch America offices or Bnei Baruch America affiliates in the country in which you reside and in other countries.

7.5. Information Sharing with Third Parties

7.5.1. This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

7.5.2. Bnei Baruch America may utilize third-party service providers and data processors that process your Personal Information solely on Bnei Baruch America’ behalf (“Agents”). When Bnei Baruch America transfers your Personal Information to its Agents, your Personal Information will be used only for limited and specified purposes. Bnei Baruch America will take reasonable and appropriate steps to ensure that its Agents process your personal information in a manner consistent with the organization’s obligations under the Principles. Bnei Baruch America remains responsible and liable if the Agents that Bnei Baruch America engages to process your Personal Information on Bnei Baruch America’ behalf do so in a manner inconsistent with this Online Privacy Policy, unless Bnei Baruch America proves that it is not responsible for the event giving rise to the damage.

7.5.3. Bnei Baruch America uses consultants and third party vendors, and may share your Personal Information with such consultants and vendors, if necessary, for delivery or administration of the Bnei Baruch America Services. All parties with which Bnei Baruch America shares your personal information are bound by confidentiality and data transfer agreements consistent with this Online Privacy Policy. Bnei Baruch America’ agreements with third parties provide that third parties will delete your personal information upon request.

7.5.4. Bnei Baruch America may share aggregated demographic information with our partners and advertisers. This is not linked to any Personal Information that can identify any individual person.

7.5.5. Bnei Baruch America uses outside third parties to ship orders and financial service-oriented third parties to bill users for goods and services. All parties with which Bnei Baruch America shares your Personal Information are bound by confidentiality and data transfer agreements consistent with this Online Privacy Policy and the Privacy Shield Principles.

7.5.6. Bnei Baruch America may partner with third parties to provide other specific services, including, but not limited to registration for Bnei Baruch America courses, classes, webinars, retreats, conventions, meetings, physical gatherings and events, and other Bnei Baruch America educational materials and Services. When the user signs up for these services, we may share names, or other contact information that is necessary for the third party to provide these services. Bnei Baruch America may auto-populate forms utilized by these third parties with data contained in Bnei Baruch America managed cookies. These third parties are not allowed to use your Personal Information except for the purpose of providing these services. All parties with which Bnei Baruch America shares your Personal Information are bound by confidentiality and data transfer agreements consistent with this Online Privacy Policy and the Privacy Shield Principles.

7.6. Other Possible Disclosures.
In addition to the other disclosures stated herein, Bnei Baruch America may share your information in the following ways:

7.6.1. To comply with applicable laws, regulations, legal processes, or government enforced orders,

7.6.2. To enforce applicable terms of service, protect our legal rights or defend against legal claims,

7.6.3. To defend, prevent, take action, and otherwise address security or technical issues, as well as suspected or potential fraud,

7.6.4. To comply with Bnei Baruch America’ obligations to address complaints arising under its obligations, including disclosure to EU Data Protection Authorities, or other necessary entities.

7.6.5. To guard against harm (whether actual or potential) to the legal rights, property or safety of Bnei Baruch America, our visitors or the general public as required or permitted by law.

8. International Transfers

8.1. We share your personal data within Bnei Baruch America. This will involve transferring your data outside the European Economic Area (EEA).

8.2. Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

9. Bnei Baruch America Purposes In Using Personal Information

We have set out below, in a table format, a summary of the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer, student or member.	(a) Identity (b) Contact (c) Financial	Performance of a contract with you
To register you for Bnei Baruch America classes, courses, webinars, events, conferences and programs.	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Financial (f) Transactional	a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To conduct the classes, courses, keeping record of attendees, webinars, forums, mentoring, educational programs and otherwise provide the Services.	(a) Identity (b) Contact (c) Profile (d) Audio-Visual (e) User Contributions	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to enable your full participation, and to enable full functionality of the website, provide educational content, and to enable full functionality of the Services).
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey (c) Managing Bnei Baruch America member services. (d) Administering, maintaining monitoring, and managing Bnei Baruch America degrees, certifications, and related examinations and programs.	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Financial (f) Transactional	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) User Contributions	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and improve our services to our users)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical (g) User Contributions	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, and to inform our marketing strategy)
To develop new marketing materials and advertising.	(a) Audio-Visual (b) User Contributions	Necessary for our legitimate interests to grow and develop and grow our educational services.
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage (c) Audio-Visual	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our products and educational services)

10. Data retention

10.1. We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

10.1. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

11. Bnei Baruch America Email Uses

11.1. Bnei Baruch America never rents or sells email addresses to outside parties without your consent. Occasionally, you may wish to receive information or communication from a Bnei Baruch America participant. In that instance, you will be asked for permission to share your email address.

11.2. After you create an online account with Bnei Baruch America, you will receive information about Bnei Baruch America products, services, and educational offerings that relate to your areas of interest unless you choose to opt-out. If you have questions or concerns about Bnei Baruch America’ Online Privacy Policy or wish to no longer receive such offers (opt-out), please contact Bnei Baruch America Customer Service using the contact information provided below.

12. How to Access or Change Your Personal Information

12.1. To review or make changes to the content of your Personal Information, or to request that we limit the use of your Personal Information, you may make changes and updates by logging into your user profile and making such changes. Alternatively, you may request such changes by contacting Bnei Baruch America Customer Service using the contact information provided below.

12.2. In your request, clearly state what information you would like to have changed or updated. Bnei Baruch America will try to comply with your request as soon possible.

12.3. The deletion of Personal Information and other changes to the data retained by Bnei Baruch America as described above may result in the deletion or limitation of the Services Bnei Baruch America provides, including, but not limited to, maintaining and making accessible Bnei Baruch America classes, courses, videoconferences, and other Services. Bnei Baruch America may retain certain Personal Information to pursue legitimate business interests, fulfill contract obligations, conduct audits, comply with (and demonstrate compliance with) other legal obligations, resolve disputes, and enforce agreements.

13. Your Legal Rights. You have the right to:

13.1. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

13.2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

13.3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

13.4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

13.5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

13.5.1. If you want us to establish the data’s accuracy.

13.5.2. Where our use of the data is unlawful but you do not want us to erase it.

13.5.3. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

13.5.4. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

13.6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

13.7. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

14. Verification

Bnei Baruch America will regularly self-assess its compliance with all applicable laws regarding Personal Information that is received from the EU. Bnei Baruch America’s statement on verification and related self-assessment procedures is available to you upon request.

15. Notices of Changes to Privacy Policy

In the event of any change to the Bnei Baruch America Online Privacy Policy, notice of such changes will be posted on the Bnei Baruch America website. Any changes to this Online Privacy Policy will become effective when we post the revised Online Privacy Policy on the Bnei Baruch America website. Your use of the Bnei Baruch America website following these changes means that you accept the revised Online Privacy Policy.

16. Contact Bnei Baruch America

For any questions, comments, or further information concerning the terms of this Online Privacy Policy, or to request changes to your Personal Information, subject to such limitations as provided herein, please contact:

Bnei Baruch America Customer Service
[email protected]

KabU Customer Service
[email protected]

BNEI BARUCH – CALIFORNIA PRIVACY RIGHTS NOTICE

Effective Date: 1^st June 2020
Last Reviewed on: 20^th June 2020

This Privacy Notice for California Residents supplements the information contained in Bnei Baruch America’s Online Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“Personal Information”). Personal information does not include:

Publicly available information from government records.
Deidentified or aggregated consumer information.

In particular, we have collected the following categories of personal information from its consumers within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	NO
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	YES
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	YES
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES

We obtain the categories of personal information listed above from the following categories of sources:

Directly from you. For example, from forms you complete or products and services you purchase.
Indirectly from you. For example, from observing your actions on our Website.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
To provide, support, personalize, and develop our Website, products, and services.
To create, maintain, customize, and secure your account with us.
To process your requests, purchases, transactions, and payments and prevent transactional fraud.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your personal information with the following categories of third parties:

Service providers.
Data aggregators.

Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category D: Commercial information.
Category F: Internet or other similar network activity.
Category G: Geolocation data.
Category H: Sensory data.
Category J: Non-public education information.
Category K: Inferences drawn from other personal information.

We disclose your personal information for a business purpose to the following categories of third parties:

Service providers.

Sales of Personal Information
In the preceding twelve (12) months, Company had not sold personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us at the Contact Information listed herein below.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights
We do not knowingly permit individuals under 18 to use the Website. We do not sell the personal information of consumers.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which Bnei Baruch America collects and uses your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Website: https://kabuconnect.com
Email: [email protected]
Postal Address:
Bnei Baruch America, Inc
7253 Watson Rd
Suite 1031
Saint Louis, MO 63119

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