1. Introduction.
   Spirituality for Kids International, Inc., a California 501(c) nonprofit corporation (“SFK,” “we,” “our,” or “us“), respects your privacy, and we recognize that it is important that you have choices and are informed about how we use and protect your information. To meet these goals, our privacy policy statement (“Privacy Policy” or “Policy“) complies with the General Data Protection Regulation (“GDPR).

This Privacy Policy describes:
• The types of information we may collect or that you may provide when you register as a user, access or use our services, or purchase a product on our Services;
• Our practices for collecting, using, maintaining, protecting, and disclosing that information; and
• How you control your privacy.

This policy applies only to information we collect on our Services and in email, text, and other electronic communications sent through or in connection with our Services.

This policy DOES NOT apply to information that:

• We collect offline or any websites you may access through our Services, including on any other websites operated by us; or
• You provide to or is collected by any third party, including through any application or content (including advertising) that may link to or be accessible from or through the Website. These third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.

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, do not register an account or access or use our Services. By registering an account or accessing and using our Services, you expressly agree to the terms and conditions of this Privacy Policy.

2. Changes to the Privacy Policy.
   This Policy may change from time to time, and the most current version can be reviewed on this page. When we make changes to our Privacy Policy, you will be notified by e-mail and required to accept the new terms prior to your continued use of the Services. You should read any changes to these terms carefully because by clicking your acceptance to any changes to the terms of this Policy, you consent to be bound by such changes.
3. Consent.
   You represent that you are at least 18 years of age. By consenting to this Privacy Policy, you are giving us permission to process your Personal Data specifically for the purposes identified in this Policy. Your consent is required for SFK to process your personal data. To the extent we ask you for any sensitive Personal Data (such as racial identity, gender, or financial information), we will always tell you why and how the information will be used.

You may withdraw consent at any time as set forth below in Section 19.

4. Children’s Privacy.

You must be 18 years of age or older to use the SFK Services. No one under age 13 may provide any personal information to our Services. We do not knowingly collect Personal Data from children under the age of 13. If you are under 13, do not use or provide any information on our Services, register on our Services, make any purchases through the Services, use public comment features of the Services, provide any information about yourself to us, including your name, address, telephone number, email address, or any user name you may use. If we learn we have collected or received Personal Data 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 the age of 13, please contact us at info@sfk.org.

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

5. Why We Request and Process Your Information.
   SFK may collect and/or process information from you because we have a legal reason (allowed by law or under contract) to collect the information or because you have consented for us to do so for a specific purpose, such as facilitating your use of our Services and the purchasing of products on our Services.
6. Information You Provide to Us.
   When you register with, access, or use our Services, you may give us information about you with your consent, for example:

• You may be personally identified, such as name, postal address, email address, telephone number, or any other identifier by which you may be contacted online or offline (” Personal Data“).
• You may provide information that is about you but individually does not identify you, such as the type of mobile device you use, your mobile device’s unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browsers you use, and information about the way you use the SFK Services.
• This includes information that you provide on our Services, including information provided at the time of registering an account to use our Services, applying for the SFK Certification Program, subscribing to our Services, posting comments to blogs and similar community features, and requesting further services.
• We may also ask you for information when you report a problem with our Services.
• We may request records and copies of your correspondence (including email addresses and phone numbers) if you contact us.
• We may request your response to surveys that we may ask you to complete for research purposes.
• We will use details of transactions you carry out through our Services and for the fulfillment of your orders. You may be required to provide financial information before placing an order through our Services.
• We may request your search queries on the Services.
• You may provide information to be published or displayed (” Posted“) on public areas of websites you access through our Services, such as comments to blog postings (collectively, “User Content“). Your User Content is posted and transmitted to others at your own risk. We cannot control the actions of third parties with whom you may choose to share your User Content. Therefore, we cannot and do not guarantee that your User Content will not be viewed by unauthorized persons.

7. Automatic Information Collection and Tracking.
   When you access and use our Services, we may use technology to automatically collect certain information about your equipment, browsing actions, and patterns, including:

• Usage Details. When you access and use the SFK Services, we may automatically collect certain details of your access to and use of our Services, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through our Services, including information regarding any website you visited before or after accessing our Services.
• Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.
• Stored Information and Files. The SFK Services also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio, personal contacts, and address book information.

8. Information Collection and Tracking Technologies.
   The technologies we use for automatic information collection may include:

• Cookies (or mobile cookies). A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting, you may be unable to access certain parts of our Services.
• Pixel Tags. Pages of the SFK Services and our emails may contain small electronic files known as pixel tags (also referred to as clear gifs, web beacons, and single-pixel gifs) that permit SFK, for example, to count users who have visited those pages or opened an email and for other related webpage statistics (for example, recording the popularity of certain webpage content and verifying system and server integrity).

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.

9. Third-Party Information Collection.
   When you use our Services or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:

• Analytics companies (such as Google Analytics).
• Your mobile device manufacturer if you access the Services through a mobile phone.
• Your mobile service provider or internet service provider. These third parties may use tracking technologies to collect information about you when you use our Services. The information they collect may be associated with your Personal Data, or they may collect information, including Personal Data, about your online activities over time and across different websites, apps, and other online services websites.

We do not control these third parties tracking technologies or how they may be used. If you have any questions about the tracking technologies used by such third parties and how this information may be used or how you may opt out of such tracking, you should review the privacy policy of these third parties.

We use Google Analytics which utilizes data collected to track and examine the use of Services to prepare reports on its activities and share them with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network. Data processed by Google Analytics is processed in the US. You may review Google Analytics Privacy Policy and Opt-Out procedure.

10. How We Use Your Information.
    We use information that we collect about you or that you provide to us, including any Personal Data, to:

• Provide you with our Services and its contents and any other information, products, or services that you request from us.
• Fulfill any other purpose for which you provide it.
• Give you notices relevant to your account and/or the Certification Program.
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
• Notify you when updates are available to our Services and of changes to any products or services we offer or provide through it.
• Allow you to participate in interactive features of our Services.
• In any other way, we may describe when you provide the information.
• For any other purpose, with your consent

The usage information we collect helps us to improve our Services and to deliver a better and more personalized experience by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize the SFK Services according to your individual preferences and use.
• Recognize you when you use the SFK Services.
• We use the location information we collect to facilitate your use of the Services more effectively.

11. Disclosure of Your Information.
    We may disclose aggregated information about our users and information that does not identify any individual or device without restriction.

In addition, we may disclose Personal Data that we collect or you provide:

• To our affiliates and partners for the purposes described in this Privacy Policy, including to be consistent with our goal of providing our users with a superior product and consumer experience.
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them and that are in compliance with the GDPR.
• 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 SFK’s assets, whether as an onward transfer or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by SFK about our users is among the assets transferred.
• 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 our rights arising from any contracts entered into between you and us, including the Terms of Use for our Services and/or the Terms and Conditions of Certification Program and Licensing.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of SFK’s customers and others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
• We may share or disclose your non-private, aggregated, or otherwise non-personal information or the number of users who clicked on a particular link.

12. Handling of Payments
    Payment processing services enable the Services to process payments by credit card, debit card, or third-party payment processing. To ensure greater security, the Services share only the information necessary to execute the transaction with the financial intermediaries handling the transaction. We do not store your financial information. Some of these services may also enable the sending of timed messages to you, such as emails containing invoices or notifications concerning the payment.

PayPal (PayPal Inc.)

PayPal is a payment service provided by PayPal Inc., which allows you to make online payments using their PayPal credentials. PayPal is PCI compliant, and you may review PayPal’s US Privacy Policy or EU/UK Member Privacy Policy.

Authorize.net provides payment gateway services to process credit card and debit card payments and is PCI compliant. You may review authorize.net’s Privacy Policy.

13. Your Choices About Our Collection, Use, and Disclosure of Your Information.
    We strive to provide you with choices regarding the Personal Data you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of your information.
    • Opt-Out Rights. You can stop all collection of information by SFK by discontinuing the use of our Services. You can also request to opt-out via email at info@sfk.org.
    • Tracking Technologies. You can set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. You can choose whether or not to allow SFK’s Services to collect information through other tracking technologies by disabling or blocking cookies. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the SFK Services may then be inaccessible or not function properly.
    • Location Information. You can choose whether or not to allow the SFK Services to collect and use real-time information about your device’s location through the device’s privacy settings.
    • Promotion by the Company. If you do not want us to use your email address to promote our products or services, you can opt out by sending us an email stating your request to info@sfk.org.
    • Advertising and Disclosure of Your Information for Advertising and Marketing. Your user data, which may include Personal Data, may be utilized for advertising communication purposes displayed in the form of banners and other advertisements on the Services, possibly based on your interests. This does not mean that all Personal Data is used for this purpose. Cookies may be used to identify users, or behavioral retargeting technique may be used, i.e., displaying ads tailored to the user’s interests and behavior, including those detected outside our Services. To the extent SFK provides advertising by any third party, you may opt out of a third-party service’s use of cookies by visiting the Network Advertising Initiative opt-out page.

Residents of certain states, such as California, Nevada, Colorado, Connecticut, Virginia, and Utah, may have additional personal information rights and choices. Please see Your State Privacy Rights for more information.

14. Accessing, Controlling, and Correcting Your Personal Information.
    You can review and change your Personal Information by logging into our Services and visiting your account setup page.

You may request details of Personal Information which we hold about you under the GDPR. A small fee will be payable to send you the information if sent by certified mail or similar service. If you would like a copy of the information held on you, please write to Spirituality for Kids International, Inc., c/o Village Workspaces, 11845 W Olympic Blvd., Suite 1100W, Los Angeles, CA 90064. You may also send us an email at info@sfk.org to request access to, correct, or delete any Personal Information that you have provided to us. In most circumstances, we will not be able to delete your Personal Information except by also deleting your user account. However, you can always delete or change your information by accessing your account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Content from the Services, we will make all reasonable efforts to remove such User Content from our Services, however, you understand that copies of your User Content may remain viewable in cached and archived pages or might have been copied or stored by other users or visitors. Proper access and use of information provided on our Services, including User Content, is governed by our Terms of Use.

Residents of certain states, such as California, Nevada, Colorado, Connecticut, Virginia, and Utah, may have additional personal information rights and choices. Please see Your State Privacy Rights for more information.

15. Storage of Your Personal Data and Data Security.
    We have implemented technology and security policies, rules, and other measures to protect your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. We also protect your information by requiring that all our employees and others who have access to or are associated with the processing of your data respect your confidentiality. In addition, we have reasonable security measures in place in our physical facilities to protect against the loss or misuse of information at our site that we have collected from you. All information you provide to us is stored in the United States on our secure servers behind firewalls. You consent to our transfer of your Personal Information outside the EU/European Economic Area (“EEA“) as part of our standard business practice, including fulfillment of your orders, payment processing, and technical support services.

We may also utilize backup-saving management services, which save and manage backups of our Services on external servers managed by the service provider itself. The backups may include the source code and content as well as the data that you provide the Services.

The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, 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 Services. The information you share in public areas may be viewed by any visitor to or user of our Services.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted through our Services. Any transmission of Personal Data is at your own risk. In the event of a data breach, we will provide you with timely notification in compliance with the GDPR.

16. Retention of Your Personal Data
    SFK will not retain your Personal Data for longer than required. We will keep your Personal Data:

• For as long as required by law
• Until we no longer have a valid reason for keeping it
• Until you request us to stop using it

We may keep just enough of your Personal Data to ensure that we comply with your requests not to use your Personal Data or comply with your right to erasure. For example, we must keep your request to be erased, even if it includes your personal data, until such time as you are no longer our customer. If you have questions about our data retention policy, please contact us by e-mail at info@sfk.org.

17. Withholding Consent to Give Personal Data
    If the Personal Data is necessary in order to supply goods or services to you under a contract between you and SFK, then we will not enter into that contract or provide the services or goods if you do not give us your Personal Data.
18. Your State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their Personal Information. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our App that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to info@sfk.org or write us at: Spirituality for Kids International, Inc., 11845 W Olympic Blvd., Suite 1100W, Los Angeles, California 90064.

Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:

• Be Informed. You have the right to be informed as to what SFK does with your Personal Data, which will be published in this Privacy Policy.
• Withdraw consent at any time. You have the right to withdraw consent where you have previously given your consent to the processing of your Personal Data.
• Object to processing of your data. You have the right to object to the processing of your Data if the processing is not carried out on a legal basis other than consent.
• Access your Data. You have the right to learn if your data is being processed by SFK, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification.You have the right to verify the accuracy of your data and ask for it to be updated or corrected.
  Restrict the processing of data. You have the right, under certain circumstances, to restrict the processing of your data. In this case, SFK will not process your data for any purpose other than storing it.
• Data Portability. You have the right to obtain and reuse your personal data for your own purposes across services in a safe and secure way without this affecting the usability of your data. Please contact us if you want information on how to port your data elsewhere at info@sfk.org. This right only applies to personal data that you have provided to us. The data must be held by us by your consent or for the performance of a contract.

Colorado, Connecticut, and Virginia also provide their state residents with rights to:

• Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose.
• Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

Lodge a complaint. You have the right to bring a claim before the competent data protection authority in your jurisdiction. Erasure of Information – this is sometimes called “the right to be forgotten.” You have the right to have all of your Personal Data erased to the extent SFK has no legal reason to continue to process and hold such Personal Data.

Nevada provides its residents with a limited right to opt out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request to this designated address: info@sfk.org. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

19. Contact Information.
    If you have any questions or comments about the Privacy Policy or the practices relating to our Services, or you wish to verify, correct or delete any Personal Data we have collected, you may contact us at: Spirituality for Kids International, Inc., 11845 Olympic Blvd., Suite 1100W, Los Angeles, California 90064, or by email at info@sfk.org.