Comprehensive Privacy Policy for the Protection and Processing of Personal Data

This Privacy Policy is designed to comply with the California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA), Federal Trade Commission Act (FTC Act), , and other applicable federal and state regulations. It details how Cowboy English Education LLC (“Company”) collects, processes, stores, protects, and shares personal data through its website www.cowboyenglish.com (“Website”) and mobile applications. As a Company, we are committed to safeguarding user privacy and maintaining the highest standards of data security. This policy provides transparency in how personal data is managed throughout its lifecycle.

1. Information About the Data Controller

Cowboy English Education LLC, as the Data Controller, is responsible for collecting, processing, and protecting personal data in accordance with applicable laws. All personal data processing activities are conducted in compliance with legal and regulatory obligations.

• Company Name: Cowboy English Education LLC
• Address: 8 THE GREEN, SUITE D, DOVER, DELAWARE 199011
• Email: support@cowboyenglish.com

For any inquiries or requests related to this Privacy Policy, you can reach us using the contact information provided above.

Personal Data Collected from Students

We collect personal data from users through various channels, including the Website, mobile applications, email communications, phone calls, and social media platforms (e.g., Instagram, WhatsApp).

Personal Data Collected from Students

• Identity Information: Name, surname
• Contact Information: Phone number, email address.
• Demographic Information: Country, date of birth
• Education Preferences: Education level, learning preferences, availability
• Referral Information: Source of referral and related details.
• Uploaded Files: Educational materials and assignments provided by students.
• Chat History: Written and verbal communication with instructors and staff.

Personal Data Collected from Instructors

• Identity Information: Name, surname, nickname, profile photo.
• Contact Information: Phone number, email address, home address.
• Demographic Information: Country, date of birth
• Professional and Academic Information: Academic background, CV, work experience.
• Financial Information: Bank account details, name on card.
• Identification Documents: Social security number or other government-issued IDs
• Promotional Materials: Introduction videos, teaching methods, written descriptions.
• Availability and References: Work schedule and references.
• Chat History: Written and verbal communication with students.

3. Purpose of Processing Personal Data

The personal data collected is processed solely to provide and improve services, enhance user experience, and fulfill legal obligations. The purposes of processing are categorized as follows:

General Purposes for All Users

1. Account Management: Managing user accounts created via the Website or mobile applications.
2. Service Delivery and Improvement: ve Providing educational services, enhancing user experience, and optimizing service processes
3. Billing and Payment Management: Processing service fees, instructor payments, and issuing invoices.
4. Marketing and Communication: Sending targeted offers, promotions, and updates tailored to user interests.
5. Compliance with Legal Obligations: Fulfilling tax regulations, responding to regulatory authorities, and complying with other legal requirements.
6. Internal Auditing and Reporting: Enhancing service quality through audits and internal reporting processes.
7. Reference Verification: Sharing limited user information (e.g., names) as references for new applicants.

Specific Purposes for Instructors

1. Selection and Evaluation: Assessing instructors based on academic qualifications, resumes,and references
2. Payment Processing: Facilitating payments using financial details provided by instructors.
3. Identity Verification: Validating identity and address for compliance with legal obligations
4. Promotion and Skill Showcase: Sharing instructors’ introductory materials (videos, descriptions) with students.

4. Data Retention Period

Personal data is retained only for as long as necessary to fulfill the purposes outlined in this policy or as required by applicable laws. Once the purpose for data retention ceases or the legal retention period ends, personal data is securely deleted, destroyed, or anonymized. Regular audits ensure compliance with retention schedules and the safe disposal of outdated data.

5. Sharing and Transfer of Personal Data

Collected personal data may be shared with the following entities in accordance with applicable laws:

• Business Partners: To facilitate service delivery and improvement.
• Technology Providers: For software development, maintenance, and technical support.
• Legal and Financial Advisors: To meet legal and financial obligations.
• Payment Processors: For secure financial transactions.

International Data Transfers

Currently, personal data is not transferred outside the U.S. If international transfers become necessary in the future, user consent will be obtained, and all legal requirements will be followed.

6. Rights of Data Subjects

Under U.S. laws (e.g., CCPA), data subjects have the following rights:

1. Access Right: To know whether their personal data is being processed and verify its accuracy
2. Rectification Right: To request corrections to incomplete or inaccurate data.
3. Deletion Right: To request the deletion of personal data under specific conditions
4. Data Portability Right: To receive a copy of their data in a commonly used format.
5. Opt-Out Right: To opt out of the sale or sharing of personal data.
6. Right to Lodge Complaints: To raise concerns about data processing practices.

To exercise your rights, contact support@cowboyenglish.com Requests will be addressed within 30 days, unless an extension is permitted by law.

7. Data Security Measures

The Company employs robust technical and administrative measures to protect personal data, including:

• Encryption: Ensuring secure storage and transmission of data.
• Access Controls: Implementing two-factor authentication to safeguard access
• Firewalls and Antivirus Software: Protecting against unauthorized access and malicious threats.
• Regular Security Audits: Reviewing and updating security protocols to maintain data integrity.

8. Cookie Policy

The Website uses cookies to enhance user experience and analyze site performance. Types of cookies include:

• Necessary Cookies: Essential for core Website functionality.
• Performance Cookies: Tracking site usage to improve performance.
• Functional Cookies: Supporting enhanced user experience.
• Targeting Cookies: Delivering personalized advertisements and offers.

For more details, refer to the "Cookie Policy" section on the Website.

9. Changes to the Privacy Policy

This Privacy Policy may be updated periodically to reflect changes in practices or legal requirements. Updates will be communicated via the Website or email notifications. Users are encouraged to review this policy regularly.

10. Children’s Privacy

The Platform does not knowingly collect personal data from individuals under the age of 13, in compliance with COPPA (Children’s Online Privacy Protection Act) If data belonging to a minor is inadvertently collected, it will be deleted immediately. For concerns, contact support@cowboyenglish.com

11. Contact Information

For questions, concerns, or complaints about this Privacy Policy, please contact:

• Email: support@cowboyenglish.com
• Address: 8 THE GREEN, SUITE D, DOVER, DELAWARE 199011