Privacy Policy

×

This Privacy Policy applies to our current and future online and
mobile websites, applications, and digital services and covers data collection,
usage and sharing practices among KLG, its affiliates and unaffiliated third
parties. Please take the time to read the full privacy policy. You consent to
the data collection, use, disclosure and storage practices described in this
privacy policy when you use the Website, any of our Services (as described
below), including when you access any digital content.

Thank you for visiting this website, a digital service presented
to you by KLG Education Services, Ltd. ("KLG", "we" or
"us"). Your privacy is important to us. As such, we provide this
privacy policy ("Privacy Policy") explaining our online information
practices and the choices you can make about the way your information is
collected and used by this digital service and among KLG’s current and future
affiliated and operated digital services ("KLG Network"), which
includes any current or future online or mobile websites, applications or
digital services owned, operated or offered by, on behalf of, or in conjunction
with KLG or its Affiliates, including any online or mobile website, application
or digital service installation through which this Privacy Policy appears (each
a "Service," collectively the "Services").
"Users" are persons that use the Services.

I. The Information We Collect

We receive both information that is directly provided to us, such
as personal information you provide when you visit the Website, and information
that is passively or automatically collected from you, such as anonymous
information collected from your browser or device. In this Privacy Policy, we
refer to all of this as the "Information."

  1. Information
    You Provide To Us.

At some Services, you
can register and subscribe to one of our services such as our online
newsletters or text message alerts. In the course of these various offerings,
we often seek to collect from you various forms of information, such as: name,
address, e-mail address, telephone number, fax number and credit card
information.

  1. Information
    That is Passively or Automatically Collected.

We, and our
"Partners" who include KLG Affiliates, third party service providers,
agencies, and distribution or other partners may use automated means to collect
various types of Information about you, your computer or other device used to
access our Services.

A representative,
non-exhaustive list of the types of automatically collected information may
include: network or Internet protocol address and type of browser you are using
(e.g., Chrome, Safari, Firefox, Internet Explorer), the type of operating
system you are using, (e.g., Microsoft Windows or Mac OS), the name of your
Internet service provider (e.g., Comcast, Verizon or AT&T) and domains used
by such providers, mobile network, device identifiers (such as an Apple IDFA or
an Android Advertising ID), device settings, browser settings, the web pages of
the Services you have visited, Services visited before and after you visit a
Service, the type of handheld or mobile device used to view the Service (e.g.,
iOS, Android), location information, and the content and advertisements you
have accessed, seen, forwarded and/or clicked on.

Please see our Section
titled Cookies, and Other User and Ad-Targeting Technologies for more
information about how the foregoing Information may be collected and used.

  1. Information
    Collected By and From Social Media Services and Other Third Party
    Platforms.

You also can engage with
our content, such as video, applications, and other offerings, on or through
social media services or other third-party platforms, such as Facebook, or
other third-party social media plug-ins, integrations and applications. When
you engage with our content on or through social media services or other
third-party platforms, plug-ins, integrations or applications, you may allow us
to have access to certain Information in your profile.

This may include your
name, e-mail address, photo, gender, birthday, location, an ID associated with
the applicable third-party platform or social media account user files, like
photos and videos, your list of friends or connections, people you follow
and/or who follow you, or your posts or "likes." For a description on
how social media services and other third-party platforms, plug-ins,
integrations or applications handle your information, please refer to their
respective privacy policies and terms of use, which may permit you to modify
your privacy settings.

When we interact with
you through our content on third party websites, applications, integrations or
platforms, we may obtain any information regarding your interaction with that
content, such as content you have viewed.

II. How We Use the Information

We, along with our Affiliates, may use the Information to:

  1. provide and
    communicate with you about the Services or your account with us;
  2. fulfill your
    requests regarding the Services, including without limitation requests for
    newsletters and notifications;
  3. respond to
    your inquiries, and notify you about matters related to our Services;
  4. communicate
    with you about programs or services that we believe may be of interest to
    you;
  5. enforce the
    legal terms (including without limitation our policies and terms of
    service) that govern your use of our Services, and/or for the purposes for
    which you provided the Information,
  6. provide
    technical support for the Services;
  7. prevent fraud
    or potentially illegal activities (including, without limitation,
    copyright infringement) on or through the Services;

p

  1. rotect the
    safety of our Users;
  2. customize or
    personalize ads, offers and content made available to you based on your
    visits to and/or usage of the Services or other online or mobile websites,
    applications, platforms or services, and analyze the performance of those
    ads, offers and content, as well as your interaction with them;
  3. perform
    analysis regarding how you use the Services or any part thereto.

When you provide information from your social media account, it
can help enable us to do things like (1) give you exclusive content, (2)
personalize your online experience with us within and outside our Services, (3)
contact you through the social media service or directly by sending you the latest
news, special offerings, and changes to itineraries, and (4) enable you to
share your experience and content via social media services. When you provide
information about yourself to us through an application, through our Services,
or on social media services or other third-party platforms, it may be publicly
viewed by other members of these services and we cannot prevent further use of
the information by third parties. We may use "cookies" or similar
technologies to associate certain of the Information with a unique identifier
that then associates the Information with your device or browser. For
information about how these technologies work and how we may use them, please
go to Section IV, titled Cookies, And Other User and Ad-Targeting Technologies.
Sometimes, we may associate cookies with the Information, including
de-identified, "hashed," or anonymous versions of Information you
have provided (such as during registration), in order to send or help our
Partners send ads and offers based on your presumed interests or demographic
information. We may combine any of the Information we collect, for any of the
above purposes, and may sometimes enhance the Information with other
information that we obtain from third party sources. Please also be aware that
if you choose to submit Information or content for publication (e.g., a letter
to our editors, comments sent to our television personalities, a posting to a
blog or a discussion board, or a video), we may publish that Information and
content, along with other Information about you (such as your name, screen name
or location). Likewise, if you register and create a profile with our Service,
the screen name you select as well as other content you submit to your profile
(e.g., photos, comments, video, reviews) will be displayed publicly on the
Service, is searchable, can be found by third parties and may be reused and
redistributed by us in our sole discretion. See our Terms of Use for details on
our use of content you submit.

III. Information Sharing and
Disclosure

We may disclose the Information as follows:

  1. Service
    Providers.

To service providers or
Affiliates that we have engaged to perform business-related functions on our
behalf. This may include service providers that: (a) conduct research and
analytics; (b) create content; (c) provide customer, technical or operational
support; (d) conduct or support marketing (such as email or advertising
platforms); (e) fulfill orders and user requests; (f) handle payments; (g) host
our Services, forums and online communities; (h) administer contests; (i)
maintain databases; (j) send or support online or mobile advertising; and (k)
otherwise support our Services.

  1. Legal Process.

In response to legal
process, for example, in response to a court order or a subpoena, a law enforcement
or government agency’s request or similar request.

  1. Prevent Fraud.

With third parties in
order to investigate, prevent, or take action (in our sole discretion)
regarding potentially illegal activities, suspected fraud, situations involving
potential threats to any person, us, or the Services, or violations of our
policies, the law or our Terms of Use, to verify or enforce compliance with the
policies governing our Services.

  1. Intra-Company
    Transfer.

W

e may transfer some or
all of your Information if we, or one of our business units, undergoes a
business transition, like a merger, acquisition by another company, or sale of
all or part of our assets, or if a substantial portion of our or of a business
unit’s assets is sold or merged in this way.

We may share the
Information with KLG Affiliates, so they can provide, improve and communicate
with you about their own, or their marketing partners’ products and services.

Please note that the Services covered by this Privacy Policy may
offer content (e.g., promotions, applications, or social network integrations)
that is sponsored by or co-branded with identified third parties. By virtue of
these relationships, the third parties may obtain information from their
visitors. We have no control over these third parties’ use of this information,
which is subject to their own privacy policies.

IV. Cookies and Other User and
Ad-Targeting Technologies

We use cookies and other technologies both to provide our Services
to you and to advertise to you. We also may work with Affiliates to help them
advertise to you when you visit other websites or mobile applications, and to
help them perform user analytics. These technologies may also be used to
analyze how our Users interact with advertising on our Services and elsewhere,
and more generally, to learn more about our Users and what services or offers
you might prefer to receive. We describe some of these technologies below.

  1. Cookies.

To enhance your online
experience, we and our Partners use "cookies", "web
beacons" or other tracking technologies. Cookies are text files placed in
your computer’s browser to store your preferences. We use cookies or other
tracking technologies to understand Service and Internet usage and to improve
or customize the products, content, offerings, services or advertisements on
our Services. For example, we may use cookies to personalize your experience at
our Services (e.g., to recognize you by name when you return to a Service),
save your password in password-protected areas, and enable you to use shopping
carts on our Services. We also may use cookies or other tracking technologies
to help us offer you products, content, offerings or services that may be of
interest to you and to deliver relevant advertising when you visit this
Service, or when you visit other websites or applications.

We or a third-party
platform with whom we work may place or recognize a unique cookie on your
browser to enable you to receive customized content, offers, services or
advertisements on our Services or other sites. These cookies contain no
information intended to identify you personally. The cookies may be associated
with de-identified demographic or other data linked to or derived from data you
voluntarily have submitted to us (e.g., your email address) that we may share with
a service provider solely in hashed, non-human readable form.

We, our third-party
service providers, advertisers, advertising networks and platforms, agencies,
or our Partners also may use cookies or other tracking technologies to manage
and measure the performance of advertisements displayed on or delivered by or
through the Turner Network and/or other networks or Services. This also helps
us, our service providers and Affiliates provide more relevant advertising and
information.

  1. Syncing
    Cookies and Identifiers.

We may work with
Affiliates (for instance, third party ad platforms) to synchronize unique,
anonymous identifiers (such as those associated with cookies) in order to match
uniquely coded user identifiers to our own. We may do this, for instance, to
enhance data points about a particular unique browser or device, and thus
enable us or others to send ads that are more relevant, match Users to their
likely interests, or better synchronize, cap, or optimize advertising.

Locally Stored Objects.
Services on the KLG Network may employ locally stored objects
("LSOs") and other client side storage tracking technologies in
certain situations where they help to provide a better user experience, such as
to remember settings, preferences and usage similar to browser cookies, or in
order to target or help our Partners target ads, analyze advertising
performance, or perform user, website or market analytics. For LSOs utilized by
Adobe Flash you can access Flash management tools from Adobe’s website. In
addition, some, but not all browsers, provide the ability to remove LSOs,
sometimes within cookie and privacy settings.

  1. Disabling
    Cookies

Most web browsers are
set up to accept cookies. You may be able to set your browser to warn you
before accepting certain cookies or to refuse certain cookies. However, if you
disable the use of cookies in your web browser, some features of the Services
may be difficult to use or inoperable.

We may work with certain
third-party companies that use techniques other than HTTP cookies to recognize
your computer or device and/or to collect and record information about your web
surfing activity, including those integrated with our Services. Please keep in
mind that your web browser may not permit you to block the use of these
techniques, and those browser settings that block conventional cookies may have
no effect on such techniques.

  1. Web Beacons.

We and
our Affiliates may also use "web beacons" or clear GIFs,

or similar technologies,
which are small pieces of code placed on a Service or in an email, to monitor
the behavior and collect data about the visitors viewing a Service or email.
For example, web beacons may be used to count the users who visit a web page or
to deliver a cookie to the browser of a visitor viewing that Service. Web beacons
may also be used to provide information on the effectiveness of our email
campaigns (e.g., open rates, clicks, forwards, etc.).

  1. Mobile Device
    Identifiers and SDKs.

We also sometimes use,
or partner with publishers, publisher-facing, or app developer platforms that
use mobile Software Development Kits ("SDKs"), or use an SDK with a
mobile app that we offer, to collect Information, such as mobile identifiers
(e.g., IDFAs and Android Advertising IDs), and Information connected to how
mobile devices interact with our Services and those using our Services. A
mobile SDK is the mobile app version of a web beacon (see "Web
Beacons" above).

T

he SDK is a bit of
computer code that app developers can include in their apps to enable ads to be
shown, data to be collected, and related services or analytics to be performed.
We may use this technology to deliver or help our Partners deliver certain
advertising through mobile applications and browsers based on information
associated with your mobile device. If you’d like to opt-out from having ads
tailored to you in this way on your mobile device, please follow the
instructions in the "Your Ad Choices" section below.

By visiting the Service,
whether as a registered user or otherwise, you acknowledge, and agree that you
are giving us your consent to track your activities and your use of the Service
through the technologies described above, as well as similar technologies
developed in the future, and that we may use such tracking technologies in the
emails we send to you.

V. Your Ad Choices

Advertising enables us to provide the rich content for which our
Services are known, and to provide much of this content free of cost to our
Users. Thus, we strive to provide you with ads that are relevant to you and for
products you may want.

However, we also offer you choices with regard to interest-based
ads.

To learn more about interest-based ads and the choices available
to you, please visit our Ad Choices page, which has general information about
certain companies that place these ads.

You may also find more information about entities involved in
online advertising and additional choices you may make through the Network
Advertising Initiative ("NAI") at the NAI Service, and the Digital
Advertising Alliance (the "DAA") at the DAA consumer choice Service.
Turner is a participant in the online industry’s self-regulatory program
administered by the DAA and has agreed to adhere to the DAA’s principles
applicable to interest-based ads. The tools provided on the Ad Choices page, as
well as the DAA opt-out page and the NAI opt-out page are provided by third
parties, not Turner. Turner does not control or operate these tools or the
choices that advertisers and others provide through these tools.

When using a mobile application, you may receive tailored
in-application advertisements. Depending on your device, you may be able to
reset your mobile device’s advertising identifier at any time by accessing the
privacy settings on your mobile device. In addition, each operating system, iOS
for Apple phones, Android for Android devices and Windows for Microsoft
devices, provides its own instructions on how to prevent the delivery of
tailored in-application advertisements. You may review the support materials
and/or the privacy settings for the respective operating systems in order to
opt-out of tailored in-application advertisements. For any other devices and/or
operating systems, please visit the privacy settings for the applicable device
or contact (or review the applicable privacy web page of) the applicable
platform operator.

VI. Other Important Information
About Your Privacy

  1. How We Respond
    to Do Not Track Signals

At this time Services on
the KLG Network do not recognize automated browser signals regarding tracking
mechanisms, which may include "do not track" instructions.

  1. Linked
    Services

Some of the Services
contain links to or integrations with other services such as Facebook, Twitter,
LinkedIn, and other media services and platforms whose information practices
may be different than ours. Visitors should consult these other services’
privacy notices as we have no control over information that is submitted to, or
collected by, these third parties.

  1. International
    Transfer

This Service is governed
by and operated in accordance with US law. If you are located outside of the
US, you use this Service at your own risk. KLG is a company that operates
globally so it is necessary to transfer your Information internationally. In
particular, your Information will be transferred to and processed in the United
States where many of our central databases operate.

By using this Service,
you (a) acknowledge that the data protection and other laws of other countries,
such as the United States, may provide a less comprehensive or protective
standard of protection than those in your country, and consent to your
Information being collected, processed and transferred as set forth in this
Privacy Policy and US law.

  1. Data Security

We have put in place
physical, electronic, and managerial procedures designed to help prevent
unauthorized access, to maintain data security, and to use correctly the
Information we collect online. These safeguards vary based on the sensitivity
of the Information that we collect and store.

Although we take
appropriate measures to safeguard against unauthorized disclosures of
Information, we cannot assure you that Information will never be disclosed,
altered or destroyed in a manner that is inconsistent with this Privacy Policy.

  1. How You Can
    Access or Correct Information

Access to certain
personal Information that is collected from our Services and that we maintain
may be available to you. For example, if you created a password-protected
account within our Service, you can access that account to review the
Information you provided.

You may also send an
e-mail or letter to the following e-mail or street address requesting access to
or correction of your personal Information. Please include your registration
information for such service such as first name, last name and e-mail address
in the request. We may ask you to provide additional information for identity
verification purposes, or to verify that you are in possession of an applicable
email account.

E-mail
Administration KLG Education Services, Ltd.
Attention: Privacy Policy Coordinator
4799 Olde Towne Parkway – Suite 100
Marietta, Georgia 30068-4399
Telephone: 770-988-8181
Email:
Rachel V. Katz

  1. How to Contact
    Us/Opting Out of Marketing Communications

If you have any
questions or concerns about the online Privacy Policy for this Service or its
implementation, or if you would like to opt out from our sharing of your
personal Information with unaffiliated third parties for the third parties’
direct marketing purposes you may contact our Privacy Policy Coordinator at the
above address and request that we opt you out of such sharing. We may ask you
to provide additional information for identity verification purposes, or to
verify that you are in possession of an applicable email account.

If you have signed up to
receive our e-mails and prefer not to receive marketing information from this
Service, follow the "unsubscribe" instructions provided on any
marketing e-mail you receive from this Service. If you have signed up to
receive text messages from us and no longer wish to receive such messages, you
may follow the instructions to stop the delivery of such messages, which may
include by replying "STOP" to the received text message.

  1. California
    Residents — Your California Privacy Rights

California’s "Shine
the Light" law, Civil Code section 1798.83, requires certain businesses to
respond to requests from California customers asking about the business’
practices related to disclosing personal information to third parties for the
third parties’ direct marketing purposes. Alternately, businesses may have in
place a policy not to disclose personal information of customers to third
parties for the third parties’ direct marketing purposes if the customer has
exercised an option to opt-out of such information-sharing. We have such a
policy in place.

As discussed above in
How to Contact Us/Opting Out of Marketing Communications, if you wish to
opt-out of our sharing of your personal Information with third parties for the
third parties’ direct marketing purposes or to find out more about your opt-out
rights, please contact our Privacy Policy Coordinator as described above.

VII. Updates & Effective
Date

From time to time, we may update this Privacy Policy. We will
notify you about material changes by either sending an email message to the
email address you most recently provided to us or by prominently posting a
notice on our Website.

We encourage you to periodically check back and review this policy
so that you always will know what information we collect, how we use it, and
with whom we share it. The Privacy Policy posted on this Service was issued on
18 January 2018.