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Privacy Policy 

We recognize that you may be concerned about our use and disclosure of your personal information. Your privacy is very important to us, and the following will inform you of the information that we, First Stroke Mobile Swim School LLC., may collect from you, and how it is used. By using our website, www.firststrokemobileswim.com, you are accepting the practices described in this policy.

What is Personal Information?
“Personal Information” is information that identifies or relates to a particular individual. Examples of Personal Information include, among others, name, email address, phone number, mailing address, and online identifiers.

2. How We Use Personal Information
We use Personal Information the following purposes:
· Providing our Service to you, including allowing you to create a profile and connect with other users;
· Analyzing, administering, and improving the Service;
· Processing payment information;
· Enabling secure use of the Service;
· Sending information and promotional materials;
· Responding to inquiries or reports of misconduct;
· Enforcing our Terms of Use;
· Protecting our rights or our property;
· Meeting legal obligations; and
· For other purposes related to the reasons for which you provide Personal Information.

3. Types of Personal Information We Collect and Use
A. Information that You Provide Us
In providing the Service, we (or our Franchisees) request information from you via forms. The exact information we need to collect (including Personal Information) will depend on the purpose of the form and type of Service requested. 
For example, when you sign up to create an account, we may ask for your and, when applicable, your child(ren)’s name, phone number, email address, date of birth, and gender identity. You will also have the opportunity to complete your or your child(ren)’s profile information (e.g., your interests, occupation) and to submit live and prerecorded video through the Service. If you want to subscribe to the Service, we will also collect payment information (which is processed securely through a third-party payment processor).
We will indicate on the form whether a particular field of information is mandatory or optional. If you choose not to provide certain information, we may not be able to provide requested services. Any information we receive from you about your child(ren) may be solely used to provide the Service and for our own internal business purposes.
B. Information We Automatically Collect from You
We collect the following types of information automatically through your use of the Service:
· Cookies, Device Identifiers, and Similar technologies
When you use or access the Service, we and our service providers use cookies, device identifiers, and similar technologies such as pixels, web beacons, and local storage to collect information about how you use the Service. We process the information collected through such technologies, which may include or be combined with Personal Information, to help operate certain features of the Service, to enhance your experience through personalization, and to help us better understand the features of the Service that you and other users are most interested in. 
Most browsers provide you with the ability to block, delete, or disable cookies, and your mobile device may allow you to disable transmission of unique identifiers and location data. If you choose to reject cookies or block device identifiers, some features of the Service may not be available or some functionality may be limited or unavailable. Please review the help pages of your browser or mobile device for assistance with changing your settings.
Some of our service providers may use cookies or other methods to gather information regarding your use of the Service, and may combine the information in these cookies with any Personal Information about you that they may have. The use of such tracking information by a third party depends on the privacy policy of that third party. We do not respond to Do Not Track (“DNT”) signals sent to us by your browser at this time. To learn more about how DNT works, please visit http://allaboutdnt.com/.
· Analytics
To assist us with analyzing our website traffic through cookies and similar technologies, we use analytics services, including Google Analytics. For more information on Google Analytics’ processing of your information, please see “How Google uses data when you use our partners' sites or apps.” 

· Log File Information
When you use our Service, our servers automatically record information, including your Internet Protocol address (“IP Address”), browser type, referring URLs (e.g., the site you visited before coming to our Service), domain names associated with your internet service provider, information on your interaction with the Service, and other such information (collectively, “Log File Information”). We may also collect similar information from emails sent to you which then help us track which emails are opened and which links are clicked by recipients.
We use Log File Information collected from our implementation of the Service to help secure the Service by identifying potential threats and vulnerabilities and in analyzing the effectiveness of our Service to improve the Service’s function and content. 

4. Disclosure of Personal Information
We will not disclose Personal Information except as set forth in this Privacy Policy or with your consent. Specifically, we do not sell Personal Information. This section describes to whom we disclose Personal Information and for what purposes:
· Our Service Providers. We employ service providers to perform tasks on our behalf and to assist us in operating the Service or providing our products and services. For example, we engage third parties to provide analytics services, infrastructure hosting, enable video communication between users, communicate with you, customer service, and payment processing. We take commercially reasonable steps to help ensure our service providers provide at least the same level of protection for Personal Information as we do.
· Our Franchisees, subsidiaries, and affiliates. We provide your information to our independently owned franchises (“Franchisees”) in order to facilitate the provision of the Service and to send you information and promotional materials you have requested from or about such Franchisee or their services. If you wish not to be contacted by our Franchisees you may utilize the “opt out” feature in any email you receive. We also provide your information to our subsidiaries and affiliates in connection with the operation of our business. We take commercially reasonable steps to help ensure our service providers, Franchisees, subsidiaries and affiliates provide at least the same level of protection for Personal Information as we do.
· Companies Involved in Mergers and Acquisitions Transactions. If we sell or otherwise transfer part or the whole of our business or assets to another organization (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, or liquidation), any information collected through the Service, including Personal Information, may be among the items sold or transferred.
· Law Enforcement, Government Agencies, and Courts. We may disclose Personal Information at the request of law enforcement or government agencies or in response to subpoenas, court orders, or other legal process to establish, protect, or exercise our rights or to defend against a legal claim or as otherwise required or allowed by law, or to protect the rights, property, or safety of any other person. We may also disclose Personal Information to investigate or prevent a violation by you of any contractual or other relationship with us or your illegal or harmful activity. 

5. How We Protect the Confidentiality of Personal Information
We protect the confidentiality and security of information we obtain in the course of business. We use commercially reasonable safeguards, such as industry-standard encryption technology, to help keep the information collected through the Service (including credit card information) secure.
Despite these efforts to store Personal Information in a secure operating environment, we cannot guarantee the security of Personal Information during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of Personal Information, we cannot guarantee that our security measures will prevent third parties such as hackers from illegally obtaining access to Personal Information. We do not represent or warrant that Personal Information about you will be protected against, loss, misuse, or alteration by third parties.

6. Accessing, Updating, or Deleting Personal Information
Users of the Service may log into the Service and correct or update certain Personal Information. 
If you would like to otherwise access, update, or delete Personal Information about you, you may submit a request to privacy@streamlinebrands.com.We will promptly review all such requests in accordance with applicable law.

7. Opting Out of Receiving Electronic Communications
With your permission, we may send notifications, promotions, or other information via email or text message (“Communications”). You may choose to stop receiving Communications by indicating your preference in your account profile or settings. Please note that certain Service-related Communications are necessary for the proper functioning and use of the Service (e.g., to verify the phone number associated with your account) and you may not have the ability to opt out of those Communications. 

8. Personal Information Transferred from the U.S.
If you are using the Service from outside the United States, please be aware that Personal Information may be transferred to, stored, and processed in the United States. Although we take steps to provide adequate safeguards, the data protection laws of the United States might not be as comprehensive as those in your country. By using the Service, you consent to your information being transferred to the United States for the purposes described in this Privacy Policy. 

9. Children’s Privacy
Children are expressly prohibited from using the Service. We do not knowingly collect or solicit any Personal Information from children. In the event that we learn that we have collected Personal Information from a child, we will promptly take steps to delete that information.

10. Other Websites and Services, Including Social Media
We are not responsible for the practices employed by any websites or services linked to or from our Service, including the information or content contained within them. A link to a third party’s website should not be construed as an endorsement. We encourage you to investigate and ask questions before disclosing Personal Information to third parties. 

11. Changes to Our Privacy Policy
We may modify or update this Privacy Policy from time to time, so please review it periodically. We may provide you with notice of material changes to the Privacy Policy as appropriate under the circumstances. Unless otherwise indicated, any changes to this Privacy Policy will apply immediately upon posting to the Service. 

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