Privacy Policy

2.1 Information You Provide Directly to Us

2.2 Automated Collection & Email Analytics

System & Usage Data: IP address, device type, operating system version, unique device identifiers, browser type/language, referring/exit URLs, click data, pages viewed, time spent, search queries, error logs, and approximate location (city/country).

Email Analytics (Clear GIFs & Web Beacons): Emails sent by us may contain web beacons or tracking pixels to record delivery, open rates, and link clicks to measure campaign effectiveness.

2.3 Social Media, Third Parties & Sensitive Data Handling

Social Media Connections: Logging in via social networks (Google, Apple, Meta, Twitter) allows us to receive profile data (name, email, profile picture) controlled by your privacy settings on those platforms.

Data Enrichment Sources: We may receive business contact details or demographic information from trusted commercial sources and analytics partners to enrich our records and personalize your experience.

Non-Collection of Sensitive Personal Data: We do not knowingly collect Sensitive Personal Data (e.g., social security numbers, government ID numbers, racial origin, political opinions, health data, or biometric identifiers). Please do not submit such data to us.

2.4 Children's Privacy

Our Services are intended for users who meet the minimum age requirement set out in our Terms of Service (currently 18 years of age) and are not directed to children. We do not knowingly collect Personal Data from anyone under that minimum age. If we become aware that we have inadvertently collected Personal Data from someone under the minimum age, we will delete it promptly. A parent or guardian who believes we may have collected such information may contact us at admin@unniclass.com.

4.1 Strict Student-Instructor Data Isolation Policy

We share certain engagement data with course instructors (such as your country, browser language, course enrollment, and review content) to help them improve their course quality. However, we NEVER share a student's actual email address with instructors or teaching assistants.

4.2 Service Providers (Processors)

4.3 Public Forums, Testimonials & UGC

Comments, reviews, and forum posts you submit are publicly viewable. These submissions are non-confidential, may be indexed by search engines, and may be used by us in marketing testimonials.

4.4 Corporate Transfers & Legal Compliance

Legal Demands: Disclosures required by subpoenas or court orders. Notice will be provided unless legally prohibited or where notice would create a risk of fraud or obstruction of justice.

Business Restructuring: In M&A, asset sales, or insolvency—including during due diligence/contemplation phases—data may be transferred as a business asset subject to prior notification.

5.1 Email as Our Primary Communication Channel

ClassAround is based in the Republic of Korea and communicates with you primarily through the email address associated with your account, which serves as our core contact database for both transactional messages (receipts, course access, policy notices) and promotional messages. You may unsubscribe from promotional emails at any time; transactional/administrative emails will continue regardless (see Section 6.3). We do not currently send marketing SMS, MMS, or automated phone calls.

5.2 Cookie Management & Ad Network Opt-Outs

We use Strictly Necessary, Functional, Performance, Advertising, and Social Media cookies. You may manage cookies via browser settings or opt out of targeted advertising via the Network Advertising Initiative (NAI), Digital Advertising Alliance (DAA), or Google Ads Settings.

5.3 Global Privacy Control (GPC)

We process legally mandated Global Privacy Control (GPC) opt-out preference signals for targeted advertising.

6.1 Access, Correct, Delete & Restrict

You may access, update, or request erasure or temporary suspension of processing of your Personal Data.

6.2 Opting Out of Profiling

You have the right to opt out of automated profiling that produces legal or similarly significant effects.

6.3 Marketing Emails vs. Administrative Notices

Unsubscribing from promotional emails stops marketing messages, but you will continue to receive transactional/administrative emails (receipts, policy updates, security alerts).

6.4 Post-Termination UGC Retention

Even after your account is deleted, certain content you shared publicly (comments, forum posts) may remain visible if copied, shared by others, or posted to third-party platforms.

6.5 Requests & Appeals

Submit privacy requests to admin@unniclass.com. We target a response within 30 days, and in all cases will respond within the timeframe required by applicable law, which may be longer (for example, up to 2 months under GDPR for complex requests, or up to 45–90 days under certain US state laws as described in Section 10.2). Where a right to appeal a denied request applies under applicable law, you may appeal our decision by emailing admin@unniclass.com within the timeframe specified in the applicable law or, absent a specific statutory period, within thirty (30) days.

9.1 Legal Bases for Processing (GDPR Art. 6)

10.1 California Notice at Collection (CCPA/CPRA)

We collect 10 categories of personal info (Credentials, Identifiers, Demographics, Transactions, Device IDs, System info, Internet Activity, Location, Payment info, Content). We do not knowingly collect Sensitive Personal Information as defined under CPRA.

Targeted Ad Opt-Out & Financial Incentives: Sharing data for targeted ads may constitute a "sale/sharing" under state laws (Opt-out via Cookie Preferences or GPC). Promotional discount coupons offered for newsletter signups constitute financial incentives under CCPA.

10.2 Rights Across US States with Comprehensive Privacy Laws

Residents of California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia, and any other state with a comprehensive consumer privacy law in effect, may exercise the rights granted under their state's law, which may include access, correction, deletion, and data portability. The specific rights available, and whether a right to appeal a denied request applies, vary by state — for example, certain states' laws do not provide a right to correction, a right to opt out of profiling, or a right to appeal. Requests may be submitted to admin@unniclass.com. We target a response within 30 days, and in all cases will respond within the timeframe required by applicable state law (which may be up to 45 days, extendable by an additional 45 days where permitted, or up to 90 days under certain states' laws such as Iowa's).

10.3 Identity Verification & Authorized Agents

Before completing an access, correction, deletion, or portability request, we will take reasonable steps to verify the requester's identity, typically by matching the request to the email address and other information already associated with the account, or through additional verification steps where required by law. Consumers may designate an authorized agent to submit a request on their behalf; we may require proof of the agent's authorization and separately verify the consumer's identity before honoring the request.

10.4 California "Shine the Light"

California residents may request, once per calendar year and free of charge, disclosure of the categories of personal information we shared with third parties for those third parties' own direct marketing purposes during the preceding calendar year, along with the names of those third parties. Submit such requests to admin@unniclass.com. As described in Section 4.2, our current service providers process your data on our behalf and do not use it for their own independent direct marketing purposes; if this changes, we will identify the specific recipients in our response to your request.

Designated Data Protection Officer (DPO / Privacy Team)

If you have any questions or requests regarding your personal information or this Privacy Policy, please contact our Data Protection Officer at:

Name: Jungwoo Choi

Title: Data Protection Officer (or Privacy Team)

Address: 3F, 611 Seonneung-ro, Gangnam-gu, Seoul, Republic of Korea

E-mail: admin@unniclass.com

EU/UK Representative:Where required under Article 27 of the GDPR or the UK GDPR, ClassAround will appoint a representative established in the EEA and/or the UK, and will publish that representative's name and contact details in this Section. Until such an appointment is made, EEA and UK data subjects may exercise their rights and raise any GDPR/UK GDPR-related matter directly with us at admin@unniclass.com, and we will respond as the data controller.