Privacy Policy

Last Updated: September 24, 2022

This Privacy Notice explains how Business Class, Inc. (“Business Class,” “we,” “us” or “our”), as the operator of the website www.sophiaamoruso.com (the “Website”) and the products and services provided through the Website (together with the Website, the “Services”), collects, uses, discloses, and otherwise processes personal information in connection with our Services. This Privacy Notice is not a contract and does not create any legal rights or obligations. When we use the term “Services”, we are referring only to the Services that we offer on our own behalf and any additional websites and mobile applications that post or link to this Privacy Notice.

This Privacy Notice does not cover or address personal information and privacy practices relating to our employees and other personnel.

Region-Specific Disclosures

We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain countries, regions or states. Please refer below for disclosures that may be applicable to you:

If you are a resident of the State of California in the United States, please see below for additional California-specific privacy disclosures.
If you are a resident of the State of Nevada in the United States, please see this additional Nevada-specific privacy disclosures:

Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us at privacy@sophiaamoruso.com.

If you are based in the European Economic Area, Switzerland or the United Kingdom, please see below for additional European-specific privacy disclosures.

1. What is Personal Information?

When we use the term “personal information” in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to you.

2. Our Collection of Personal Information

From the first moment you interact with us, we are collecting personal information about you. Sometimes we collect personal information automatically when you interact with our Services and sometimes we collect the personal information directly from you. At times, we may collect personal information about you from other sources and third parties, even before our first direct interaction.

Personal Information You Provide

We collect the following personal information you provide in connection with our Services:

Contact Information, including your name, social media handle, address, telephone number and email address when you purchase a product, register for our courses, sign up to receive our newsletters, or otherwise communicate with us.
Account Information, including your username and password for the Services.
Payment and Transaction Information, including payment information, credit information, and order details when you purchase products from us. Payments may be processed by third-party payment processors. Please refer to the applicable processor’s terms and privacy policy for more information about how payment information is processed and stored.
Sensory Information, including pictures you choose to provide or upload in connection with the Services.
Inquiry Information, including the content of your emails to us.
Employment Information, including your job title, department, employer or business, demographic information, demographic and work history, work eligibility information and information obtained from your resume, when you submit an application for employment with us.

Personal Information Automatically Collected

As is true of most digital platforms, we collect certain personal information automatically when you visit our online Services, including:

Log File Data, including your internet protocol (IP) address, operating system, browser type, browser id, date/time of visit, and pages visited.
Analytics Data, including the electronic path you take to our Services, through our Services and when exiting our Services, as well as your usage and activity on our Services, such as the links and object you view, click or otherwise interact with (also known as “Clickstream Data”).
Location Data, including your general geographic location based on your IP address or more precise location when accessing our online Services through a mobile device.

For information about our and our third-party partners’ use of cookies and related technologies to collect information automatically, and any choices you may have in relation to its collection, please visit our Cookie Notice .

Personal Information from Other Sources and Third Parties

We also obtain personal information from other sources, which we often combine with personal information we collect either automatically or directly from you.

We may receive the same categories of personal information as described above from the following sources and third parties:

Service Providers: Our service providers that perform services solely on our behalf, such as payment processors and analytics providers. For example, we receive personal information from our service providers that conduct marketing or analytics activities.
Business Partners: Our business partners whom we partner with to provide joint promotional activities or co-branded services may collect personal information in connection with these activities and may share some or all of the information with us.
Publicly Available Sources: We may collect personal information about you that we do not otherwise have, including contact information and product interest information, from publicly available sources. We may combine this information with the information we collect from you directly. We use this information to contact you, to send you advertising or promotional materials or to personalize our Services, to pre-populate online forms, and to better understand the demographics of our users.
Social Networks_: _When you interact with our Services through various social media networks, such as when you “Like” us on Facebook or when you follow us or share our content on Facebook, Twitter, LinkedIn, YouTube or other social networks, we may receive some information about you that you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network. You should always review and, if necessary, adjust your privacy settings on third party websites and social media networks and services before linking or connecting them to our Services.
Other Third Parties: From time to time, we may receive information about individuals from third parties. For example, we may obtain information from our marketing partners or from third parties to enhance or supplement our existing information about you.

3. Our Use of Personal Information

We use personal information we collect to:

To fulfill or meet the reason you provided the information, for example to process payment in connection with your transactions or to respond to inquiries.
To process your registration for our Services, including verifying your information to ensure its accuracy and validity.
To identify you as a potential candidate and review your application for a position with us.
To communicate with you, including via social media messages, email, text message and/or telephone calls.
To operate, maintain, and provide the features and functionality of the Services.
To send you important information regarding the Services, such as certain changes to our terms, conditions, policies, and/or other administrative information. Because this information may be material to your use of the Services, you may not opt out of receiving such communications.
For our marketing purposes.
To help maintain the safety, security, and integrity of our Services, technology assets, and business.
For our internal business purposes, such as data analysis, customer research, audits, fraud prevention, developing new products and/or features, enhancing the Services, improving our Services and identifying usage trends.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations and our Terms of Use , or to comply with applicable laws.
For purposes disclosed at the time you provide your personal information or as otherwise set forth in this Privacy Notice.

If you choose to contact us, we may need additional information to fulfill your request or respond to your inquiry. We may provide additional privacy disclosures where the scope of the inquiry/request and/or personal information we require fall outside the scope of this Privacy Notice. In that case, the additional privacy disclosures will govern how we may process the information you provide at that time.

4. Our Disclosure of Personal Information

We may disclose personal information in the following ways:

Service Providers: We may disclose personal information with third-party vendors, consultants and other service providers who perform functions or services on our behalf. For example, we may share personal information with service providers for auditing, compliance, identifying and serving targeted advertisements, and web hosting.
Business Partners: We share personal information with third parties with whom we do business in compliance with applicable laws and subject to their separate privacy notices.
Online Advertising Partners: We also share personal information with advertising networks or permit these partners to collect information from you directly on the Website to facilitate online advertising, such as search engines and social network advertising providers to serve targeted ads to you or to groups of other users who share similar traits, such as likely commercial interests and demographics, on third-party platforms. For more information, including how to opt out of interest-based advertising, please read our Cookie Notice .
Social networks: We may disclose personal information, such as a unique identifier, hashed email address, or information automatically collected through tracking technologies, to social networks for the purpose of displaying personalized advertising and content on those social networks.
Within Business Class: We may share information between and among Business Class Inc. and its current and future parents, affiliates, subsidiaries, and other companies under common control or ownership.
Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership.
Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:
in connection with the establishment, exercise, or defense of legal claims;
to comply with laws or to respond to lawful requests and legal process;
to protect the rights and property of us, our agents, customers, and others, including to enforce our agreements, policies, and terms of use;
to detect, suppress, or prevent fraud;
to reduce credit risk and collect debts owed to us;
to protect the health and safety of us, our customers, or any person; or
as otherwise required by applicable law.
Consent: We may disclose personal information about you to certain other third parties with your consent.

5. Choices and Control Over Your Information

Profile and settings: If you purchase a product from us, you may update your account information and adjust your account settings by logging into your account. Please note that changes to your settings may require some time to take effect.

How to control your email preferences: You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Services, technical and security notices). You may also be able to adjust certain communications preferences by logging into your account.

Online advertising and tracking: Please refer to our Cookie Notice to learn more about how we work with third party partners to collect data through tracking technologies for various purposes, including analytics and advertising, and to understand your choices.

6. Children’s Personal Information

The Website and online Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. If you are under the age of 13, please do not use the Website or online Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 13 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 13, we will promptly delete that personal information.

7. Third-Party Websites

The Website and online Services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.

8. Updates to This Privacy Notice

We will update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the “Last Updated” date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify you by email to your registered email address, by prominent posting on the Website or our online Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

9. Contact Us

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to privacy@businessclass.co.

Alternatively, inquiries may be addressed to: Business Class Inc. 2046 Hillhurst Ave #73 Los Angeles, CA 90027

BUSINESS CLASS INC. CALIFORNIA PRIVACY NOTICE

Last Updated: September 24, 2022

1. Scope of Disclosures

This California Privacy Notice (the “CA Privacy Notice”) supplement the information contained in our Privacy Notice and applies solely to individual residents of the State of California (“consumers” or “you”).

This California Privacy Notice provides additional information about how we collect, use, disclose and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (“CCPA”).

Unless otherwise expressly stated, all terms in this CA Privacy Notice have the same meaning as defined in our Privacy Notice or as otherwise defined in the CCPA.

2. Personal Information Disclosures

When we use the term “personal information” in this CA Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

For the purposes of this CA Privacy Notice, personal information does not include:

Publicly available information from government records.
Deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you.
Information excluded from the CCPA’s scope, such as:
Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
Information relating to our employees, contractors and other personnel.

Collection and Use of Personal Information

In the last 12 months, we have collected the following categories of personal information from the categories of sources and for the purposes set forth below, which reference the personal information, sources and purposes described in the Our Collection of Personal Information and Our Use of Personal Information sections of our Privacy Notice :

Category of Personal Information	Collected
Identifiers, such as name, email address, telephone address, address, and account username and password.	✓
California Customer Records (Cal. Civ. Code § 1798.80(e)), such as credit/debit card information or other payment information.	✓
Protected Classification Characteristics, such as demographic information including your age and gender (for job applicants only).	✓
Commercial Information, such as payment details and information about products or services purchased, obtained or considered.	✓
Internet/Network Information, such as your browsing history, log and analytics data, search history and information regarding your interaction with the Services.	✓
Geolocation Data, such as information about your physical location collected from geolocation features on your device, including your IP address and GPS (e.g., latitude and/or longitude).	✓
Sensory Information, such as pictures you provide or upload in connection with the Services.	✓
Professional/Employment Information, such as job history, qualifications, experience (for job applicants only).	✓
Non-Public Education Information (20 U.S.C. § 1232g, 34 C.F.R. Part 99) , such as educational history, degree (for job applicants only).	✓
Other Personal Information, such as personal information you provide us in relation to a question, request or inquiry or your social media handle when you interact with us on social media.	✓
Inferences, including information generated from your use of our Services reflecting predictions about your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.	✓

‍

We collect personal information about you from one or more of the following sources:

Directly from you
Indirectly from you
Service Providers
Business Partners
Social Networks
Your browser or device
Generated or derived from other personal information

Please note: In addition to the categories of sources identified above, we may collect information from publicly available sources and other third-party information providers in order to supplement the information we have otherwise collected.

Purposes for Collecting Personal Information

We collect, use, sell or disclose personal information about you for one or more of the following purposes:

To fulfill or meet the reason you provided the information, for example to process payment in connection with your transactions or to respond to inquiries.
To process your registration for our Services, including verifying your information to ensure its accuracy and validity.
To identify you as a potential candidate and review your application for a position with us.
To communicate with you, including via social media messages, email, text message and/or telephone calls.
To operate, maintain, and provide the features and functionality of the Services.
To send you important information regarding the Services, such as certain changes to our terms, conditions, policies, and/or other administrative information. Because this information may be material to your use of the Services, you may not opt out of receiving such communications.
For our marketing purposes.
To help maintain the safety, security, and integrity of our Services, technology assets, and business.
For our internal business purposes, such as data analysis, customer research, audits, fraud prevention, developing new products and/or features, enhancing the Services, improving our Services and identifying usage trends.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations and our Terms of Use , or to comply with applicable laws.
For purposes disclosed at the time you provide your personal information or as otherwise set forth in our Privacy Notice.

Recipients of Personal Information

As described in the Our Disclosure of Personal Information section of the Privacy Notice, we share personal information with a variety of third parties for business purposes. We disclose personal information to the following categories of third parties:

Within Business Class: We may disclose personal information between and among Business Class Inc. and its current and future parents, affiliates, subsidiaries, and other companies under common control or ownership.
Business partners: We may share limited information with third parties with whom we partner to provide contests and sweepstakes, or other joint promotional activities or co-branded services.
Online advertising partners: We also share personal information with advertising networks or permit these partners to collect information from you directly on our websites to facilitate online advertising, such as search engines and social network advertising providers to serve targeted ads to you or to groups of other users who share similar traits, such as likely commercial interests and demographics, on third-party platforms.
Social networks: We may disclose personal information, such as a unique identifier, hashed email address, or information automatically collected through tracking technologies, to social networks for the purpose of displaying personalized advertising and content on those social networks.
Service providers: We share personal information with third-party vendors, consultants and other service providers who perform functions or services on our behalf and under our instructions to make the Services available to you, subject to contractual terms restricting the collection, use and disclosure of your personal information.
Third parties at your request: We share your personal information with third parties with your consent or at your direction.
Third parties in the context of a corporate transaction: We may disclose personal information as reasonably necessary to evaluate, negotiate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Business Class’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Business Class about consumers is among the assets transferred or is otherwise relevant to the evaluation, negotiation or conduct of the transaction.
Law enforcement and third parties pursuant to legal request: From time to time, we may disclose personal information as reasonably necessary to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

We do not “sell” personal information as most people would typically understand that term. However, we do allow certain advertising networks, social media companies and other third-party businesses to collect and disclose your personal information directly from your browser or device through cookies and related technologies when you visit or interact with the Website or otherwise engage with us online. Please see the Third-Party Tracking and Online Advertising section below for more information about how third parties use cookies and related technologies to collect information automatically on the Website and other online services, and the choices you may have in relation to those practices.

3. Your California Privacy Rights

As a California resident, you may be able to exercise the following rights in relation to the Personal Information about you that we have collected (subject to certain limitations at law):

The Right to Know	You have the right to request any or all of the following information relating to the personal information we have collected about you or disclosed in the last 12 months, upon verification of your identity: The specific pieces of personal information we have collected about you; The categories of personal information we have collected about you; The categories of sources of the personal information we have collected about you; The categories of personal information that we have disclosed about you to third parties for a business purpose, and the categories of recipients to whom this information was disclosed; The categories of personal information we have sold about you (if any), and the categories of third parties to whom this information was sold; and The business or commercial purposes for collecting or, if applicable, selling personal information about you.
The Right to Request Deletion	You have the right to request the deletion of personal information that we have collected from you, subject to certain exceptions.
The Right to Opt Out of Personal Information Sales	You have the right to direct us not to sell personal information we have collected about you to third parties. If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.
The Right to Non-Discrimination	You have the right not to receive discriminatory treatment for exercising any of the rights described above. However, please note that if the exercise of the rights described above limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products or services or engage with you in the same manner.
“Shine the Light”	California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code § 1798.83).

The specific pieces of personal information we have collected about you;
The categories of personal information we have collected about you;
The categories of sources of the personal information we have collected about you;
The categories of personal information that we have disclosed about you to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
The categories of personal information we have sold about you (if any), and the categories of third parties to whom this information was sold; and
The business or commercial purposes for collecting or, if applicable, selling personal information about you.

4. How to Exercise Your California Privacy Rights

To Exercise Your Right to Know or Right to Deletion

To exercise your right to know and/or right to deletion, please submit a request by:

Emailing privacy@businessclass.co with the subject line “California Rights Request,” or
Filling out our California Resident Rights Request Form.

We will need to verify your identity before processing your request. In order to verify your identity, we will generally either require the successful login to your account or the matching of sufficient information you provide us to the information we maintain about you in our systems. Although we try to limit the personal information collected in connection with a request to exercise the right to know and/or the right to deletion to that personal information identified in your request, certain requests may require us to obtain additional personal information from you. In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity or locate your information in our systems, or as permitted by law.

To Exercise Your Right to Opt Out of Personal Information Sales

As noted above, we do not “sell” personal information as most people think of that term. You may, however, exercise your right to opt out of any future potential sales by clicking the link below and following the instructions:

Do Not Sell My Personal Information

You do not need to create an account with us to exercise your Right to Opt Out of Personal Information Sales. However, we may ask you to provide additional personal information so that we can properly identify you in our dataset and to track compliance with your opt out request. We will only use personal information provided in an opt out request to review and comply with the request. If you choose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems.

Once you make an opt-out request, you may change your mind and opt back in to personal information sales at any time by contacting us at privacy@businessclass.co.

Third-Party Tracking and Online Advertising

We utilize third-party partners to engage in online advertising. These ad networks, social media companies and other third-party businesses collect your personal information directly from your browser or device through cookies or similar tracking technology when you visit or interact with our websites, or otherwise engage with us online. For example, they may collect Internet/Network information, such as a cookie or device ID, browsing history and website usage, Geolocation Data, and Inferences generated from your browsing history and interactions with our Services as well as other sites and services. These third-party businesses use your personal information to serve relevant ads on our site, on other websites or mobile apps, or on other devices you may use, or to personalize content and perform other advertising-related services such as reporting, attribution, analytics and market research. These third parties may use such personal information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties, including other advertising networks.

By visiting www.privacyrights.info or www.optout.privacyrights.info , you can opt out from sales of this type of personal information by businesses that participate in the opt out tool. To make opt-out requests related to mobile apps on your device for businesses participating in the DAA’s CCPA App-based Opt-Out Tool, you can download the appropriate app at www.youradchoices.com/appchoices . Please see our Privacy Notice and Cookie Notice or more information about how third parties use cookies and related technologies to collect information automatically on our websites and other online services, and the choices you may have in relation to those practices.

Minors Under Age 16

We do not sell the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the “Right to Opt In”) from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age.

“Shine the Light”

In addition to the rights described above, California’s “Shine the Light” law (Civil Code Section §1798.83) permits California residents that have an established business relationship with us to request certain information regarding our disclosure of certain types of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. To make such a request, please send an email to privacy@businessclass.co.

Authorized Agent

In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf where (i) you provide sufficient evidence to show that the requestor is an authorized agent with written permission to act on your behalf and (ii) you successfully verify your own identity with us.

5. Updates to These CA Disclosures

We will update these CA Disclosures from time to time. When we make changes to these CA Disclosures, we will change the “Last Updated” date at the beginning of these CA Disclosures. If we make material changes to these CA Disclosures, we will notify you by email to your registered email address, by prominent posting on our online Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.

Contact Us

If you have any questions or requests in connection with this Notice or other privacy-related matters, please send an email to privacy@businessclass.co.

Alternatively, inquiries may be addressed to: Business Class Inc. 2046 Hillhurst Ave #73 Los Angeles, CA 90027

BUSINESS CLASS INC. EUROPEAN PRIVACY NOTICE

Last Updated: September 24, 2022

Unless otherwise expressly stated, capitalized terms in this European Privacy Notice have the same meaning as defined in the Privacy Notice.

1. Scope of Disclosures

This European Privacy Notice supplements the information contained in our Privacy Notice. However, this European Privacy Notice applies only to our processing of your Personal Data where you are located in the EEA, Switzerland or the UK.

2. Personal Data Disclosures

When we use the term “Personal Data” in this European Privacy Notice, we mean any information relating to an identified or identifiable natural person.

Legal Bases for Processing

We rely on the following legal grounds to process Personal Data about you, whether it is obtained from you or a third party:

Category of Personal Data	How We Use the Personal Data	Legal Basis for Processing
Contact information, such as name, address, telephone number and email address.	We use this information to communicate with you, including sending service-related communications.	The processing is necessary for the performance of a contract between you and us, and/or to take steps at your request prior to entering into a contract.
	We use this information to send you unsolicited marketing communications in accordance with your preferences.	We will only use your Personal Data in this way to the extent you have given us consent to do so.
	We use this information to address inquiries and complaints made by you relating to your use of our Services.	The processing is necessary for our legitimate interests, namely administering our Services and for communicating with you effectively to respond to your queries or complaints.
Data collected through the use of our Services, including information about how you use our Services, your actions on our Services, including feedback through the Services.	We may use information about how you use and connect to our Services to present our Services to you on your device.	The processing is necessary for our legitimate interests, namely, to tailor our Services to the user.
	We may use this information to determine products and services that may be of interest to you for marketing purposes.	The processing is necessary for our legitimate interests, namely, to inform our direct marketing.
	We may use this information to monitor and improve our Services and business, resolve issues and to inform the development of new products and services.	The processing is necessary for our legitimate interests, namely, to monitor and resolve issues with our Services and to improve our Services generally.
Your preferences, such as preferences set for notifications, marketing communications, such as email.	We use this information to provide our Services to you in accordance with your choices.	The processing is necessary for our legitimate interests, namely ensuring our Services are displayed in accordance with the user's preferences.
	We use this information to ensure that we comply with our legal obligation to send only those marketing communications to which you have consented.	The processing is necessary for compliance with a legal obligation to which we are subject.
Payment information. When you purchase our products and Services, we will collect confirmation of your payment from the third-party payment processor.	We use this information to record that your payment has been processed and to grant you access to the paid features of our Services.	The processing is necessary for the performance of a contract between you and us, and/or to take steps at your request prior to entering into a contract.
Information provided by social networks you connect to our Services, including when you “Like”, follow or share our content on Facebook, Twitter, Instagram, YouTube or other sites. The data we receive is dependent on your privacy settings with the social network.	We use this information to promote and market our Services and increase user engagement with our products and Services.	The processing is necessary for our legitimate interests, namely promoting our products and services and increasing user engagement with our products and services.
Information contained in communications between you and us, including any information you provide when you contact us or interact with us directly, such as by submitting feedback or other information to us.	We use this information to respond to comments, questions or requests for customer service.	The processing is necessary for our legitimate interests, namely administering our Services and addressing your queries and concerns.
	We use this information to address any violations of our Terms of Use, or any other rules, regulations or policies relating to our Services.	The processing is necessary for the performance of a contract between you and us.
Information about how you access and use our Services, including usage history, and your clicking and browsing patterns.	We use this information to operate, maintain and provide to you the features and functionality of our Services, to improve our products and services, for research and product development.	The processing is necessary for our legitimate interests, namely, to tailor our Services to you, to improve our Services and to develop new features and functionalities on our Services.
Internet and network information, including device information, logs and analytics data.	We use this information to provide and monitor the effectiveness of our Services; monitor usage of and activities on our Services; diagnose errors and problems with our Services; otherwise plan for and enhance our Services; understand your activities when you use our Services to deliver ads and information about products and services that may be of interest to you.	The processing is necessary for our legitimate interests, namely, to tailor our Services to you, to improve our Services and to develop new features and functionalities on our Services.
All Personal Information set out above.	We may use this information to comply with any professional or legal obligation to which we may be subject, such as disclosure of information to comply with a court order or at the request of a regulator.	The processing is necessary for the compliance with a legal obligation to which we are subject.
	We may use this information to facilitate our internal business operations that are put in place for compliance with our legal obligations.	The processing is necessary for our legitimate interests, namely the detection and prevention of fraud and the fulfilment of professional obligations.
	We may use this information to determine products and services that may be of interest to you for marketing purposes.	The processing is necessary for our legitimate interests, namely, to inform our direct marketing.

We use the Personal Data we automatically collect about you in the following ways and rely on the following legal grounds to process Personal Data about you, whether it is obtained from you or a third party:

Category of Personal Data	How We Use the Personal Data	Legal Basis for Processing
Information about how you access our Services. For example, the site from which you came and the site to which you are going when you leave the Website, how frequently you access the Services, whether you open emails or click the links contained in emails, and whether you access the Services from multiple devices.	We or the third-party partners we use, may use the data collected through tracking technologies to: remember information so that you will not have to re-enter it during your visit or the next time you visit our Services; provide custom, personalized content and information, including targeted content and advertising; identify and contact you across multiple devices; provide and monitor the effectiveness of our Services; perform analytics and detect usage patterns on our Services; diagnose or fix technology problems; detect or prevent fraud or other harmful activities, and otherwise plan for and enhance our Services.	The processing is necessary for our legitimate interests, namely: to tailor our Services to the user and to improve our Services generally; to monitor and resolve issues; for marketing purposes; to communicate with users; to contact users; and for the detection and prevention of fraud. For more information on the legal basis for cookies, please see our Cookie Notice.
Information about how you use our Services. For example, the pages you visit, the links you click, the ads you view and click on, your purchase and subscription information, your location when you access or interact with our Services and other similar actions.
Information about the computer, tablet, smartphone or other device you use, such as your IP address, browser type, Internet service provider, platform type, device type/model/manufacturer, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account (including, for example, a persistent device identifier or an Ad ID), and other such information.
Analytics information. We may collect analytics data, or use third-party analytics tools, to help us

For more information on the legal basis for cookies, please see our Cookie Notice.

You are not required to provide Personal Data to us, but we do rely on your Personal Data to provide certain of our services and products. For example, we need your Personal Data to facilitate and deliver a service or product that you request. If you choose not to provide us with your Personal Data, we may not be able to provide you with a service or product you request.

Data Retention

We retain Personal Data about you for as long as is necessary for the purposes set out in this European Privacy Notice, unless a longer period is required under applicable law or is needed to resolve disputes or protect our legal rights.

The criteria used to determine the period for which Personal Data about you will be retained varies depending on the legal basis under which we process the Personal Data:

Legitimate Interests	Where we are processing Personal Data based on our legitimate interests, we generally will retain such information for a reasonable period of time based on the particular interest, taking into account the fundamental interests and the rights and freedoms of data subjects
Consent	Where we are processing Personal Data based on your consent, we generally will retain the information for the period of time necessary to fulfill the underlying agreement with you, subject to your right, under certain circumstances, to have certain of your data erased (please see the Your Privacy Rights section below)
Contract	Where we are processing Personal Data based on contract, we generally will retain the information for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from the contractual relationship
Legal Obligation	Where we are processing Personal Data based on a legal obligation, we generally will retain the information for the period of time necessary to fulfil the legal obligation
Legal Claim	We may need to apply a “legal hold” that retains information beyond our typical retention period where we face threat of legal claim. In that case, we will retain the information until the hold is removed, which typically means the claim or threat of claim has been resolved.

In all cases, in addition to the purposes and legal bases, we consider the amount, nature and sensitivity of the Personal Data, as well as the potential risk of harm from unauthorized use or disclosure of your personal data.

3. International Data Transfers

We may transfer Personal Data about you among us and to our subsidiaries or affiliates, as well as to the categories of third parties identified in the Our Disclosure of Personal Information section of the Notice . Personal Data may be transferred to, stored and processed in a country other than the one in which it was collected, including, but not limited to, the United States. The country to which Personal Data is transferred may not provide the same level of protection for Personal Data as the country from which it was transferred.

We may transfer Personal Data about you outside the EEA and when we do so, we rely on appropriate or suitable safeguards recognized under the GDPR including adequacy decisions, consent (where appropriate) and the standard contractual clauses.

4. Your Privacy Rights

You have the following rights in relation to your Personal Data (subject to certain limitations at law):

Access	The right to access and obtain a copy of Personal Data about you, as well as information relating to its processing.
Rectification	The right to correct or update any Personal Data about you that is inaccurate or incomplete.
Restriction of Processing	The right to require us to limit the purposes for which we process your Personal Data if the continued processing of the Personal Data in this way is not justified, such as where the accuracy of the Personal Data is contested by you.
Erasure	The right to request the deletion or erasure of Personal Data about you without undue delay if the continued processing of that Personal Data is not justified.
Portability	The right to obtain a copy of Personal Data about you in an easily accessible format and the right to transmit that Personal Data to another controller.
Objection to Processing	You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your Personal Data, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

Please note that if the exercise of these rights limits our ability to process Personal Data, we may not be able to provide our products or services to you, or otherwise engage with you going forward.

Right to Withdraw Consent

Where we rely on your consent for processing of your Personal Data, you also have the right to withdraw your consent to such processing, subject to certain limitations at law. You may withdraw your consent at any time by contacting us using the contact details at the end of this European Privacy Notice.

Submitting Requests

To submit a request, please contact us as set forth in the Contact Us section below. We may need to verify your identity before processing your request, which may require us to obtain additional personal data from you. In certain circumstances, we may decline a request to exercise the rights described above.

Right to Lodge a Complaint

If you have any complaints regarding our privacy practices, you have the right to lodge a complaint with your national data protection authority (i.e., supervisory authority). If you are based in the EEA, Switzerland or UK, information about how to contact your local data protection authority is available here . However, we encourage you to first reach out to us by using the contact details set out in the Contact Us section below so that you have an opportunity to address your concerns directly and so that we may find a solution together before you do lodge a complaint.

5. Updates to These Disclosures

We may update this European Privacy Notice from time to time. When we make changes to the European Privacy Notice, we will change the “Last Updated” date at the beginning of this European Privacy Notice. If we make material changes to this European Privacy Notice, we will notify you by email to your registered email address, by prominent posting on our online Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.

6. Contact Us

If you have any questions or requests in connection with this European Privacy Notice or other privacy-related matters, please send an email to privacy@businessclass.co.

Alternatively, inquiries may be addressed to: Business Class Inc. 2046 Hillhurst Ave #73 Los Angeles, CA 90027