Privacy Policy Effective Date: August 7, 2019 This notice describes the Privacy Policy for, an on-line web based internet service provider, and/or the web portal for Tony Gaskins Academy (as applicable, the “Website”) operated by Gaskins Productions, LLC, a Florida for profit limited liability company, d/b/a Tony Gaskins Academy.  The operation of Tony Gaskins Academy by the Company is done so under an exclusive License Agreement with Gaskins Productions, LLC. By visiting the Website, you are accepting the practices described in this Privacy Policy which are a part of the Terms of Use of the Website. We respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes the types of information we may collect from you or that you may provide when you visit the Website and our practices for collecting, using, maintaining, protecting and disclosing that information. This policy applies to information we collect: •On the Website and during registration. •In e-mail, text and other electronic messages between you and the Website. •Through mobile and desktop applications you download from the Website, which provide dedicated non-browser-based interaction between you and the Website. It does not apply to information collected by: •Us offline or through any other means, including on any other website operated by third parties (including but not limited to schools, colleges, universities and community); or •Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website. Please read this 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 to not use the Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time. Your continued use of this Website after we make changes constitutes your acceptance of those changes, so please check the policy periodically for updates. 1. Children Under the Age of 13 The Website is not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on 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, e-mail 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 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us. 2. What Personal Information About Users Do We Gather? In order to help us personalize and continually improve your experience at the Website, we gather certain types of information. The types of information we gather are:   1Information You Give Us: We receive and store any information you enter on the Website, or give us in any other way. For example, we request that you provide certain personal information, including your name, address, email address, birth date, telephone number, contact information, and any other information from which your identity is confirmed. We may also sometimes afford you the opportunity to provide descriptive, cultural, behavioral, and preferential and/or lifestyle information about yourself, but it is solely up to you whether you furnish such information. If you do provide such information, you are thereby consenting to the use of that information in accordance with the policies and practices described in this Privacy Policy. In other areas, we collect or may collect demographic information that is not unique to you such as your ZIP code, age, preferences, gender, interests and favorites. Sometimes we collect or may collect a combination of the two types of information. You can choose not to provide certain information, but then you might not be able to take advantage of certain features. We use the information that you provide to us for such purposes as responding to your requests, customizing future visits for you, improving our services, communicating with you and may provide such information to third parties for purely scholarly and non-commercial purposes. 2Automatic Information: We also receive and store certain types of information whenever you interact with us. For example, we gather or may gather certain information about your use of the Website and the Website networking, such as what areas you visit and what services you access. The Company and our partners, affiliates, and analytics or service providers use cookies or similar technologies. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. Users can control the use of cookies at the individual browser level. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis. 3 4As is true of most web sites, we gather certain information automatically and store it in log files.  This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.  We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you and site functionality.  We may partner with third parties to either display advertising on our website or manage our advertising on other sites. Our third party partners may use technologies such as cookies to gather information about your activities on this website and other sites in order to provide you with advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union, click here). Please note this does not opt you out of being served ads. You may continue to receive generic ads. 5Email Communications: We store all email correspondences between you and the Website in order to improve your future experiences. We may use your contact information in order to send you email or other communications regarding updates at the Website. While you have the option to opt-out of receiving emails, we reserve the right to send you strictly service-related announcements on rare occasions, e.g., if service is temporarily suspended for maintenance. You may opt-out by clicking the unsubscribe link from the email, or by emailing us at  If you choose to use our referral service to tell a friend about our website, we will ask you for your friend’s email address. We will automatically send your friend a one-time email inviting him or her to visit the website. We may store this information for the sole purpose of sending this one-time email and tracking the success of our referral program.  Your friend may contact us at to request that we remove this information from our database. 6Blog/Forum:  The Website may contain publicly accessible blogs or community forums.  You should be aware that any information you provide in these areas may be read, collected and used by others who access them. To request removal of your personal information from a blog or forum contact us.  In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. 3. How We Use Information We Gather We use information that we collect about you or that you provide to us, including any personal information: •To present the Website and its contents to you. •To provide you with information, products or services that you request from us. •To fulfill any other purpose for which you provide it. •To provide you with notices about your account/subscription, including expiration and renewal notices. •To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection. •To notify you about changes to the Website or any products or services we offer or provide through it. •To enable our third party partners and their assigns to conduct scholarly research. •In any other way we may describe when you provide the information. •For any other purpose with your consent. Under no circumstances will this Website sell or otherwise provide information to third party advertisers to assist in the marketing of products or services to users. 4. Disclosure of Information We will share your personal information with third parties only in the ways that are described in this privacy policy.  We do not sell your personal information to third parties. We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose personal information that does not identify any individual that we collect or you provide as described in this privacy policy: •To our subsidiaries and affiliates for various purposes. •To contractors, service providers and other third parties (examples include but are not limited to schools, colleges, universities and community partners) we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them. These companies are authorized to use your personal information only as necessary to provide these services to us. •To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by the Company about the Website users is among the assets transferred. You will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information. •To third parties for research and purely scholastic endeavors and not to advertise products or services to you. •To fulfill the purpose for which you provide it. •For any other purpose disclosed by us when you provide the information. •With your consent. We may also disclose your personal information: •To comply with any court order, law or legal process, including to respond to any government or regulatory request. •To enforce or apply our terms of use and other agreements, including for billing and collection purposes. •If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers or others. We DO NOT collect or repurpose personally identifiable information including but not limited to: •Social Security Numbers. •Home Addresses. •Credit Card Numbers. •Criminal Record. •Personal Telephone Number. We DO NOT control and are not responsible for any information provided to or disseminated by administrators or other users. All administrators and users are required to comply with the Website’s Terms of Use regarding the contribution and dissemination of information. Users may always opt out of providing information to other users or administrators. 5. Access and Choice If your personal information changes, or if you no longer desire our service, you may update this information by making the change on our member information page or by emailing our Customer Support by clicking here or by contacting us by postal mail at the contact information listed below. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. 6. Public Areas of the Website Some areas of the Website may be public areas. These are OPEN PUBLIC FORUMS and must be treated as such. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. CHOOSING TO MAKE YOUR INFORMATION PUBLIC IS EXACTLY WHAT IT SOUNDS LIKE: ANYONE, INCLUDING PEOPLE OFF OF THE WEBSITE, WILL BE ABLE TO SEE IT. THE COMPANY DOES NOT GUARANTEE THE ACCURACY OR YOUR SAFETY WHEN RESPONDING TO A STUDENT OR ORGANIZATIONAL POSTING ON ANY OF THESE FORUMS. PLEASE BE SMART AND VERIFY ANY AND ALL ORGANIZATIONS OR MEMBERS. 7. Data Security We have implemented measures designed to secure your personal information including a variety of privacy and security policies, processes and procedures, including administrative, physical and technical safeguards that reasonably and appropriately protect the confidentiality, integrity and availability of the personal information that it creates, receives, maintains or transmits from accidental loss and from unauthorized access, use, alteration and disclosure. In addition, we encrypt the transmission of such personal information using secure socket layer technology (SSL). The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website. If you have any questions about security on our Web site, you can contact us by clicking here. 8. Third Party Websites The Website may contain links to third party websites over which we have no control. We are not responsible for the privacy policies or practices of other websites. We encourage you to review the privacy policies of those other websites so you can understand how they collect, use, and share your information. Widgets and Social Media Features The Website may include Social Media Features, such as the Facebook Like button and Widgets, such as the Share this button or interactive mini-programs that run on the Website. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on the Website. Your interactions with these Features are governed by the privacy policy of the company providing it. Open ID Provider You may be able to log in to the Website through sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities on this Web site to your profile page to share with others within your network. 9. Rights Under FERPA The use of the Website does not affect your rights under the Family Educational Rights and Privacy Act (“FERPA”). Pursuant to FERPA, any school that receives funds under an applicable program of the U.S. Department of Education is required to protect the privacy of student education records. In a nutshell, FERPA requires schools to obtain written permission from parents or students prior to disclosing a student’s records. However, certain exceptions allow schools to disclose information internally, and for certain specified reasons, without obtaining consent. For more information on FERPA, please visit 10. Compliance with FERPA The Company maintains strict standards with regard to personally identifiable information about students (Student PII) to ensure compliance with FERPA. In accordance with these standards, the Company will not disclose Student PII for any other purpose other than the purpose for which it was disclosed. In addition we will not share or sell FERPA-protected information, or re-use it for any other purposes, except as directed by you or permitted by FERPA. Information disclosed on the website will not be used by us or provided to others for marketing purposes.  In addition, we have implemented security policies and procedures reasonably designed to protect Student PII from inappropriate disclosure, destruction or modification.  Any staff of Website who will come into contact with Student PII has been specifically trained to ensure the security and confidentiality of such records. If you believe Student PII contained on this Website is incorrect, inappropriately displayed or you would like to gain access to Student PII stored on this Website belonging to you or your children please contact us by clicking here. 11. Data Retention We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements. We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law for a set period. You can request to see or delete your personal data and that of any student accounts you create. You understand and agree, however, that it may not be possible to completely delete all information from our databases and in such case we may retain (but not display, distribute, or perform) server copies of your information that have been removed or deleted from your account. Even after we have deleted your information from our systems, copies of some information from your account may remain viewable in some circumstances – where, for example, you have shared information with social media platforms and other unaffiliated services, or in a de-identified or aggregated fashion. We may also retain backup information related to your account on our servers for some time after cancelation for fraud detection or to comply with applicable law or our internal security policies. 12. Data Provided by Educational Entity Notwithstanding the provisions set forth above, the following provisions shall apply only to data of whatever type (the “Data”) provided directly by an educational agency, school or university (each an “Educational Entity”). All Data containing Student PII or records which were the property of the student prior to its transfer to this Website shall continue to be the property of the student under the control of the Educational Entity. To contact this website for issues related to Student PII please click here. We will hold all Data provided by an Educational Entity in the strictest confidence and will not disclose any such Data except as provided in any agreement between the Educational Entity and us, as expressly authorized in writing by the Educational Entity or in connection with a qualified research project or scholarly pursuit. In addition, prior to any disclosure of Data required by a court of competent jurisdiction or an administrative body we will notify the Educational Entity in writing prior to any such disclosure to give the Educational Entity an opportunity to oppose any such disclosure. We will not transmit or store Data outside the United States without the consent of the Educational Entity. All Data provided by the Educational Entity will be stored, processed, and maintained solely on designated target servers and at no time will such Data be processed on or transferred to any portable or laptop computing device or any portable storage medium, unless that storage medium is in use as part of our backup and recovery processes. We will use Data provided by the Educational Entity solely for the purposes expressed in any agreement between the Educational Entity and us or for research and purely scholastic endeavors.  This Data will not be distributed, repurposed or shared across other applications, environments, or business units of the Company.  In addition, except in the case of research and purely scholastic endeavors, this Data will not be transmitted, exchanged or otherwise passed to other vendors or interested parties except on a case-by-case basis as specifically agreed to in writing by the Educational Entity. In the event of an unauthorized release of information contained in the Data provided by the Educational Entity requiring notification of the individuals affected, we shall assume responsibility for informing all such individuals in accordance with applicable law. 13. Mobile Privacy We may offer you the ability to connect with our Website, or use our applications, services, and tools through a mobile device, either through a mobile application or via a mobile optimized website. The provisions of this Privacy Policy apply to all such mobile access and use of mobile devices. This Privacy Policy will be referenced by all such mobile applications or mobile optimized websites. When you download or use our mobile applications, or access one of our mobile optimized sites, we use various technologies to determine location, such as location services of the applicable operating system or browser and sensor data from your device, such as GPS coordinates. We automatically receive and record information on our server from your browser or mobile platform, including your location, IP address, browser type, operating information, device and application IDs, and cookie information. The location data will be used solely to present you with opportunity and event distance calculations, and location verification for work service performed. We will not use any information collected for advertising purposes and we will not provide this information to any third parties for use in the marketing of any product or service to you.  Most mobile devices allow you to control or disable location services in the device's setting's menu. If you have questions about how to disable your device's location services, we recommend you contact your mobile service carrier or the manufacturer of your particular device. 14. Changes to Our Privacy Policy It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you by e-mail to the primary e-mail address specified in your account and/or through a notice on the Website home page prior to the change becoming effective. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Website and this privacy policy to check for any changes. 15. Contact Information The Website is operated by Gaskins Productions, LLC, a for profit Florida limited liability company d/b/a, which developed and owns the Website. You can contact the site by visiting the Contact Us Page.