Data Transfer Statement
This Data Transfer Statement (“Statement”) sets forth The Class Corp.’s policies and practices concerning the transfer of personal data across borders.
Applicability
This Statement applies to The Class Corp and its U.S. operating businesses, as identified below (collectively and for this statement only, “The Class,” “we” or “us”). This Statement forms a part of our privacy policy.
Location
The Class is based in the United States. We provide services globally using computer systems, servers, and databases located in the U.S. When you use our services from outside of the U.S., your information will therefore be transferred to, stored in, and processed in the U.S.
European Users
The European Commission has determined that the transfer of personal information of its residents outside of Europe must be subject to a legal framework that adequately protects it. We transfer personal information of European Economic Area (“EEA”) and Swiss residents to the U.S. (or elsewhere) based upon the following legal frameworks:
Our use of Standard Contractual Clauses (also known as “Model Clauses”) where appropriate.
Our transfer of data to vendors that comply with the EU-US and Swiss-US Privacy Shield frameworks (“Privacy Shield”).
GDPR
We comply with the European Union’s General Data Protection Law (“GDPR”), which governs the protection of personal data of EU residents. To find out more about GDPR, please visit the European Union’s website, at https://ec.europa.eu/info/law/law-topic/data-protection_en.
EU users have the rights to: opt out of cookies (see our Cookie Policy); access, correct, delete, restrict or object to our use of their personal information; be forgotten; and data portability. For the most part, we enable exercise of these rights directly through our products. For example, we allow users to change their information, download their videos, and close their accounts.
If you require assistance or have a specific request that is not presently covered by our product features, please contact our Data Protection Officer. We may require additional information from you to fulfill your requests. We may charge a reasonable fee if your request imposes an unreasonable cost on us.
We will afford UK-based users with all rights available to EU users, regardless of the UK’s EU member status.
Controllers and Processors
Some laws, including the GDPR, differentiate between controllers and processors of data. A “controller” has a direct relationship with you and exercises control over the use of your data. The third-party vendors that help a controller provide a service are considered “processors” because they process the controller’s customer data at the controller’s request (examples are payment processors and cloud-based hosting providers).
The Class is a controller of personal data relating to users who upload and live stream videos and otherwise use our services on our website.
With respect to the The Class and Digital Studio Service platforms and the other services we offer through our website, The Class is a controller of personal data of end users because The Class has direct relationships with the end user viewers.
With respect to the Digital Studio Service, The Class acts as an independent controller of the personal data submitted to the platform by persons who subscribe to Digital Studio Service.
Dispute Resolution
We are committed to working with you to obtain a fair resolution of any complaint. We encourage you to begin by contacting our Data Protection Officer. We endeavor to respond to requests promptly.
EU residents have the right to lodge complaints with the data protection authority of their country of residence.
Data Protection Officer
For any questions, inquiries, or complaints, please contact us at:
Data Protection Officer
The Class Corp
22 Park Place, 3rd Floor
New York, New York 10007