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PRIVACY STATEMENT

By: Derek Capo

Next Step China, LLC (“NSC”) is committed to protecting the privacy of NSC’s participants, and strives to provide a safe, secure Participant experience. This Privacy Statement sets forth the online data collection and usage policies and practices that apply to this website. It does not apply to information NSC collects in any other fashion.

 By clicking the “Accept”, “Submit” or other buttons during registration, or by using this site, Participant explicitly accepts, without limitation or qualification, the collection, use, and transfer of the personal information provided by Participant in the manner described in this statement. Please read this statement carefully as it affects a Participant’s rights and liabilities under the law. If Participant disagree with the way NSC collects and processes personal information collected on the website, NSC recommends that Participant do not use this website.

Scope of this Policy

This statement applies to www.NextStepChina.org (the “Site” or Sites”), which is owned by NSC. It is NSC policy to comply with data protection legislation. This regulates the processing of information relating to a Participant and grants Participant various rights in respect of a Participant’s personal data.

The Site may contain links to other websites over which NSC has no control. NSC is not responsible for the privacy policies or practices of other websites to which Participant chooses to link from this site. NSC encourages Participant to review the privacy policies of those other websites so Participant can understand how NSC collects, uses, and shares a Participant’s information.

Information collected and retained

NSC collects the following personal information used to identify a Participant, or any other individual to whom the information may relate, personally along with credit/debit card information for payment. NSC does not collect personal information unless a Participant chooses to provide it to NSC. Some examples of personal information that NSC collects for the services it renders are:

Demographic information may be collected as well.  Demographic information is information that is not unique to Participant in the sense that it refers to selected population characteristics, such as a the Participant’s ZIP code or postal code, age, preferences, gender, race or ethnicity, occupation, career history, interests and favorites.  

How information is used

NSC uses the information it gathers on the website for the purposes of advertising NSC’s programs, responding to any queries participants may have, operating and improving the website, fostering a positive Participant experience, and delivering the products and services that NSC offers participants. NSC’s service is the teaching of mandarin and Chinese cultural in China.

By registering with NSC or expressly opting in when presented with choices, a participant has consented for NSC to use Participant’s information, subject to local law, in the following ways:

By participants providing personal information for inclusion in NSC’s database, Participant acknowledges that Participant’s consents to Participant’s information being used as described herein. NSC will take measures to safeguard information from unauthorized access or inappropriate use by third parties.

Disclosure of information to others

NSC may disclose to third parties within Participant’s country and abroad using personal information, combined personal or demographic, as set forth below.

1. NSC may share Participant information with third parties who help NSC in the delivery of NSC’s own programs and services to Participant. NSC discloses information to companies and individuals NSC employs to perform functions on its behalf. Examples include hosting our web servers, analyzing data, providing marketing assistance, processing credit card payments, and providing customer service. These companies and individuals may be located in a country whose data protection legislation is different from a Participant’s country, and they will have access to Participant’s personal information as necessary to perform their functions, but they may not share that information with any other third party or use that data for any other purpose. NSC will remain the data controller and be responsible for any information shared in this way.

2. NSC may disclose such information to third parties if a Participant consents to such disclosure. For example, if a Participant indicates by selecting in his/her registration that he/she would like to receive information about the opportunities, programs or services of third parties, NSC will supply Participant’s contact information to select third parties for the purpose of sending the Participant an e-mail or otherwise communicating with the Participant. NSC will use the data NSC has about the Participant to determine whether the Participant might be interested in the other opportunities, products, or services of a particular third party or NSC.

NSC may also share aggregated anonymous information about participants of the Site with NSC’s clients, partners, other NSC visitors, and other third parties so that it can understand the kinds of participants who visit the Site and how those participants use the Site.

3. NSC will disclose information if legally required to do so, if requested to do so by a governmental entity or if NSC believes in good faith – after considering the Participant’s privacy interests and other factors – that such action is necessary to: (a) conform to legal requirements or comply with legal process; (b) protect NSC’s rights or property of NSC’s affiliated companies; (c) prevent a crime or protect national security; or (d) protect the personal safety of participants or the public. Because NSC is a US limited liability company and information collected on its Site is stored in whole or in part in the United States, the Participant’s information may become subject to U.S. law.

4. NSC may disclose and transfer such information to a third party who acquires all or a substantial portion of NSC's business, whether such acquisition is by way of merger, consolidation, or purchase of all or a substantial portion of NSC’s assets. Additionally, in the event NSC becomes the subject of an insolvency proceeding, whether voluntary or involuntary, NSC or its liquidator, administrator, receiver, or administrative receiver may sell, license, or otherwise dispose of such information in a transaction approved by the court. The Participant will be notified of the sale of all or a substantial portion of NSC’s business to a third party by email or through a prominent notice posted on the Sites.

Again, in each of these situations, the recipients of the Participant’s data may potentially be located in any country in the world. If the Participant is a resident in any EU member state, for example, the Participant must be aware that the EU authorities do not generally consider the regulations of non-EU countries to ensure an adequate or equivalent level of protection as compared to the EU data protection regulations.

Changes to privacy Statement

If NSC decides to change the substance of NSC’s Privacy Statement for NSC, NSC will, where required, contact the Participant via the email address that the Participant maintains in his/her profile. NSC will also post those changes through a prominent notice on the Site so that the Participant will always know what information NSC gathers, how NSC might use that information, and to whom NSC will disclose it.

Legal and Contact Information

The Participant’s data is submitted to NSC and is hosted and stored in a database on servers situated in the United States owned and maintained by Next Step China, LLC, a Florida limited liability company, whose principal place of business is at 80 SW 8 Street, Suite 2000; Miami, FL  33130, USA. Next Step China, Inc., a Florida corporation with its principal place of business at 80 SW 8 Street, Suite 2000; Miami, FL  33130, USA, is the legal entity determining the purposes and means of processing the information gathered at the Site and is the data controller of all data stored in the NSC’s database.  All information collected is PCI compliant.  For information on PCI compliance, please visit https://www.pcisecuritystandards.org/.

Use of Cookies, Web Beacons, and Java Script

*Cookies: NSC uses "cookies" to help personalize and maximize a Participant’s online experience and time online. A cookie is a text file that is either stored in a Participant’s computer’s memory temporarily (e.g. a “session” cookie) or placed on in a Participant’s hard drive (a “persistent” cookie) by a webpage server. Cookies are not used to run programs or deliver viruses to a Participant’s computer. Cookies are uniquely assigned to a Participant’s computer and can only be read by a web server in the domain that issued the cookie to a Participant.

When a Participant returns to the NSC site, cookies enable NSC to retrieve the information a Participant previously provided, so a Participant can easily use the features that a Participant customized. Because of NSC’s use of cookies, NSC can deliver faster and more accurate results and a more personalized site experience. For example, if a Participant personalizes NSC pages, or register for services, a cookie helps us to recall a Participant’s specific information.

NSC also uses cookies to identify participants who have been banned from using NSC Site for behavior that contradicts NSC’s terms of use and to track click streams, for load balancing and to enable a Participant to navigate through the site using redirection pages.

NSC also allows other companies to display advertisements to a Participant while a Participant is visiting NSC’s Site. Because a Participant’s web browser must request these advertisements from the other companies’ servers, these companies can view, edit, or set their own cookies, just as if a Participant had requested a webpage from their site. NSC has no control over, and is not responsible for, the practices of those third party advertisers. NSC encourages a Participant to review the policies of such advertisers. (A Participant will find additional information about the following third party ad servers at www.doubleclick.com and www.atlassolutions.com/privacy.  NSC uses other third party ad servers as well; a way to opt out of third party cookies is to modify a Participant’s browser settings to decline cookies.)

A Participant has the ability to accept or decline cookies at any time by modifying a Participant’s browser settings. If a Participant chooses to decline cookies, however, that may hinder performance and negatively impact a Participant’s experience on the website.

*Web Beacons:  NSC webpages may also contain electronic images known as Web beacons (sometimes called single-pixel gifs) that allow NSC to count participants who have visited those pages and to deliver co-branded services. Web beacons are not used to access a Participant’s personally identifiable information on NSC; they are a technique NSC uses to compile aggregated statistics about NSC’s website usage. Web beacons collect only a limited set of information including a cookie number, time and date of a page view, and a description of the page on which the Web beacon resides.

Because Web beacons are the same as any other content request included in the recipe page, a Participant cannot opt out or refuse them. However, they can be rendered ineffective by either opting out of cookies or changing the cookie setup in a Participant’s browser.

JavaScript:  NSC also uses JavaScript, for example, within certain advertisements. JavaScript is a script language that enhances the functionality of websites, particularly in respect to pictures. NSC is not collecting any personal data via JavaScript. A Participant may deactivate JavaScript via a Participant’s browser settings or activate it the same way. If a Participant disables JavaScript, a Participant will not be able to use some of the functions of the website.

Conditions of Use, Notices, and Revisions
If the Participant choose to visit Site, the Participant’s visit and any dispute over privacy is subject to this Notice and NSC’s Conditions of Use and Term of Use, including limitations on damages, resolution of disputes, and application of the law of the state of Florida. If the Participant has any concerns about privacy at the Site, please contact NSC using the Contact Us section and provide a thorough description, and NSC will try to resolve it. NSC’s business changes constantly, and NSC’s Privacy Notice, Terms of Use, and the Conditions of Use will change also. NSC may e-mail periodic reminders of NSC notices and conditions, unless the Participant has instructed NSC not to, but The Participant should check NSC’s website frequently to see recent changes. Unless stated otherwise, NSC’s current Privacy Notice applies to all information that NSC has about the Participant and his/her account. NSC stands behind the promises it makes, however, and will never materially change NSC’s policies and practices to make them less protective of customer information collected in the past without the consent of affected customers.

How to Contact Us

If, at any time, the Participant has questions or concerns about this Privacy Statement or believes that NSC has not adhered to this Privacy Statement, please feel free to email NSC at Ask@NextStepChina.org  or contact us at:

Next Step China, LLC

80 SW 8 Street, Suite 2000

Miami, FL  33130

USA

 

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