Privacy Policy

PRIVACY POLICY


NOTICE: On May 23, 2018, Marrakesh adopted an amended Privacy Policy, providing as follows:

Marrakesh cares about the confidentiality and security of your information. This Privacy Policy applies to information that Marrakesh collects through the Marrakesh Site when you interact with Marrakesh, with subscribers, with other users, and generally with the Marrakesh Site.

Your information is received and controlled by Marrakesh according to this Privacy Policy when you sign up for a Marrakesh account or otherwise use the Marrakesh Site.

★ Marrakesh is solely and independently responsible for its own privacy practices. No subscriber is responsible for Marrakesh’s privacy practices.

★ Each Subscriber is solely and independently responsible for its own privacy practices. No Subscriber is responsible for another Subscriber’s privacy practices. Also, Marrakesh is not responsible for any Subscriber’s privacy practices.

If you do not accept the terms of this Privacy Policy, then please do not access, browse, or register/sign-up for the Marrakesh Site. If you choose not to provide certain information required to provide you with various products and services offered on the Marrakesh Site, then you may not be able to establish a user account or obtain those products or services.

Any version of this Privacy Policy in a language other than English is provided for convenience and you understand and agree that the English language version will control if there is any conflict.

This Privacy Policy is organized as follows:
1. Information that Marrakesh collects from you (including Personal Information)
2. Cookies and Tracking Technologies on the Marrakesh Site
3. How your information is used
4. How your information is shared
5. How to manage your Personal Information
6. Storage & Security
7. Privacy Policy updates
8. Contact information
9. Glossary

1. Information that Marrakesh Collects from You (Including Personal Information)
Marrakesh directly collects information when you:
sign up for a Marrakesh user account and create a Marrakesh user profile;
purchase a product;
send email messages to Marrakesh;
participate in user surveys; and
participate in public forums, webinars, and other interactive experiences on the Marrakesh Site.

Marrakesh also indirectly collects usage information about your visit to the Marrakesh Site, as explained in the section below titled Cookies and Tracking Technologies.

Marrakesh does not itself collect or store financial account numbers or identification issued by a governmental entity, employer, or other authority. Instead, if you choose to make a purchase on the Marrakesh Site you will be directed to Marrakesh’s third-party payment processor and Marrakesh’s third-party ID verification service provider. If you do not wish to submit the required authentication or payment information, then you will not be able to complete your purchase via the Marrakesh Site.
To the extent that Marrakesh associates the information that Marrakesh collects directly or indirectly with an individual (for example, you), the association is based on Personal Information in your account profile.
You may voluntarily choose to share additional Personal Information on the Marrakesh Site.

Marrakesh encourages you to use discretion before voluntarily sharing additional Personal Information on the Marrakesh Site. (If you later choose to delete your Marrakesh account, deletion of your Personal Information will be subject to the process and limits outlined below.)

2. Cookies and Tracking Technologies on the Marrakesh Site
Like many companies, Marrakesh uses Cookies and other common Tracking Technologies on the Marrakesh Site and in email communications to help Marrakesh better understand your use and needs of the Marrakesh Site, current and future Marrakesh-related products and services, and how Marrakesh can improve.

For example:
based on your cookie settings, Marrakesh tracks information indicating, among other things, which pages of the Marrakesh Site were visited, the order in which they were visited, when they were visited, and which hyperlinks and other user interface controls were used;

Marrakesh may log the IP address, operating system, and browser software (including mobile use and device type when you use Marrakesh native mobile apps) you used when accessing the Marrakesh Site, and Marrakesh may be able to determine from an IP address your Internet Service Provider and the geographic location of your point of connectivity; and
Marrakesh may track and collect information from emails that Marrakesh sends to you, for example whether you opened the email or clicked on any links from the email.

Marrakesh also partners with third parties to help us track and understand your activity on the Marrakesh Site, how you interact with Marrakesh’s social media, and how you find or may be referred to the Marrakesh Site.

Marrakesh uses Cookies and other Tracking Technologies for the following purposes:

when necessary for system administration, security, and integrity to ensure the Marrakesh Site works properly for you. Without these technologies, the Marrakesh Site may not function correctly;

to enable analytics, performance and functionality, to help Marrakesh gather information about how visitors use the Marrakesh Site and monitor Marrakesh Site performance, and to enhance your experience by recognizing whether you have visited the Marrakesh Site before and may have any personal preferences; and

to support marketing by enabling Marrakesh to deliver content relevant to your interests on the Marrakesh Site and third-party sites based on how you interact with Marrakesh or third-party advertisements or content. Marrakesh use “first-party” cookies, which means cookies served by Marrakesh, and also “third-party” cookies, which means cookies served by third parties that help Marrakesh track this information.

You have some options for managing Cookies and other Tracking Technologies. These include:

Modifying your browser settings: You should be able to control how and whether your web browser accepts Cookies by adjusting its privacy and security settings. The “help” feature of the menu bar on most browsers will tell you how to stop accepting new Cookies, how to receive notification of new Cookies, and how to disable existing Cookies. If you reject Marrakesh’s Cookies, many functions and conveniences of the Marrakesh Site may not work properly.

Opting-out of certain third-party tracking and advertising: Some of the third parties used by Marrakesh or a Subscriber for Cookies and Tracking Technologies offer the ability to opt-out from their tracking by following processes described on their websites. Neither Marrakesh is responsible for the effectiveness of any third-party opt-out options.

3. How Your Information Is Used
Marrakesh use information, including Personal Information, to carry out the following purposes:

Operate and improve the Marrakesh Site – This includes creating and improving features that support the Marrakesh community and enable Marrakesh Site usage at scale. This also includes personalizing the Marrakesh Site, so your experience is tailored to your interests and needs.

Offer and improve products – This includes enabling you to navigate the Marrakesh Site, to subscribe and participate on the Marrakesh Site and to purchase or obtain products on the Marrakesh Site.

Develop and maintain the security and performance of the Marrakesh Site – This includes tracking Marrakesh Site outages and creating software solutions, detecting violations of the Terms of Service, and monitoring uses, misuses, and potential misuses of the Marrakesh Site.

Communicate with you – This includes answering your course and platform questions, notifying you of course and Marrakesh Site maintenance and updates, marketing to you about course offerings, programs, news, and related products and services of Marrakesh or Marrakesh affiliates, and as permitted under applicable law, sending you communications about products or services of selected business partners that may be of interest to you.

Support scientific research including, for example, in the areas of cognitive science and education – This includes collaborating to enable and conduct research about how learners access and master course materials online, with the goal of improving course outcomes.

Track Marrakesh Site usage against goals and mission – This includes performing analytics to evaluate access to and performance in courses and course-related products and services and to report aggregate usage information (not Personal Information) to business partners and external audiences.

Exercise, enforce, and comply with legal rights and obligations – This includes responding to subpoenas, court orders, or other legal process; and investigating, preventing, or taking action regarding illegal activities, suspected fraud, security or technical issues, or to protect the rights, property, or safety of Marrakesh or others, and as otherwise required by applicable law.

Marrakesh may also seek your consent for additional uses of information, including Personal Information, and will use it only for the purpose described to you. All use of Personal Information is subject to applicable law.

4. How Your Information Is Shared
Marrakesh share information, including Personal Information, with third parties for the following purposes:

With service providers, contractors, and other third parties that help carry out the uses described above – Marrakesh requires third parties to: (1) abide by this Privacy Policy and applicable law; (2) handle Personal Information in a confidential manner and maintain adequate security; and (3) use Personal Information only as needed to fulfill the relevant purpose(s). In some cases, the Marrakesh Site and individual courses are integrated with third-party services or contain links to websites published by third parties, including other content providers as well as service providers. These third parties are responsible for their own privacy practices, so you should pay attention anytime you are redirected to a third-party website and be sure to review its privacy policy.

With affiliates of Marrakesh or with successors in the event of a merger, acquisition, or reorganization, for their use consistent with this Privacy Policy.

Marrakesh may also seek your consent for additional disclosures of information, including Personal Information, and will share it only as described to you. In addition, Marrakesh may share with the public and with third parties, including but not limited to researchers and business partners, information and Personal Information that is de-identified or aggregated in a manner that does not personally identify you.

5. How to Manage Your Personal Information
You can manage your Personal Information and requests to the Marrakesh team. Marrakesh will notify you in the event that Marrakesh is unable to meet a request that is not legally required.

Access and correct your Personal Information
Much of your Personal Information is available in your Marrakesh account. Your name, email address, and other identifiable profile information is editable through the profile settings in your Marrakesh account except as noted below. Please contact the Marrakesh team to access and update this or other information.

Exceptions:
Usernames cannot ever be changed. This is a Marrakesh system restriction. Because usernames identify you on the Marrakesh Site, Marrakesh encourages you to use discretion in choosing your username. If you want to protect your identity, do not use your real name or a name identifiable to you as your username.

Marrakesh does not track or index every time or every place on the Marrakesh, so Marrakesh will be able to help you locate or manage all such instances. Marrakesh encourages you to use discretion before volunteering Personal Information on the Marrakesh Site.

Restrict or object to the processing of Personal Information
If you want to manage emails and other communications to you, you may update your preferences in your Marrakesh account dashboard, follow the steps described in links at the bottom of email messages, or contact the Marrakesh team. You may object to, or request that Marrakesh stop its use of your Personal Information for other purposes by contacting the Marrakesh team. Please note that if you choose to restrict Marrakesh’s ability to process Personal Information, and the processing is otherwise required to provide you with various services and products offered on the Marrakesh Site, you may not be able to establish an Marrakesh user account, and Marrakesh may not be able to provide you with those services or products.

Delete account and Personal Information
To request deletion of your Marrakesh account and Personal Information, you should click the button labeled “Delete my account” in your Marrakesh account settings. Because deletion on the Marrakesh system is a permanent action and cannot be reversed, Marrakesh may ask you to complete a process that aims to confirm your authority to manage the Marrakesh account affected by your request.

With respect to your Marrakesh account, Marrakesh will permanently:
deactivate your Marrakesh account,
remove the active profile, and
retire your username.

With respect to your Personal Information, Marrakesh will permanently delete your Marrakesh account profile Personal Information from the Marrakesh Site.

As noted above, to the extent that Marrakesh associates the information that Marrakesh collects directly or indirectly with an individual (for example, you), the association is based on Personal Information in your Marrakesh account profile. By erasing the Personal Information in your Marrakesh account profile, the remaining information about your activity on the Marrakesh Site will no longer be associated with you, except as noted below.

These changes will be applied to data stores that are used for operation of the Marrakesh Site

Exceptions:
Deletion will not apply to historical activity logs or archives unless and until these logs and data naturally “age-off” the Marrakesh system.
Marrakesh does not track or index every time or every place on the Marrakesh Site when or where a learner may volunteer Personal Information, so neither Marrakesh nor Subscribers will be able to help you locate or manage all such instances. Marrakesh encourages you to use discretion before voluntarily sharing your Personal Information on the Marrakesh Site.

Data retention
Marrakesh will retain your Personal Information for as long as your account is active or as needed to provide you with services; to maintain a record of your transactions for financial reporting, audit, and compliance purposes; and to comply with Marrakesh’s legal obligations, resolve disputes, enforce its agreements, and as otherwise permitted by applicable law. Upon your request that Marrakesh deactivate your account and delete your information, Marrakesh will follow the process described above, including without limitation archiving your course data (in a manner and to the extent permitted under applicable law) to serve its mission to enable scientific research on cognitive science and education.

6. Storage & Security
Marrakesh stores information, including Personal Information, on its own servers and also on servers of companies that Marrakesh hires to provide services. In each case, information may be stored in the United States and in other countries where Marrakesh operates, and in countries where Marrakesh respective service providers operate. If you are in the European Union, Switzerland, or other regions with laws governing data collection and use, you acknowledge that Marrakesh may transfer, process and store your personal information in the United States and other countries, the privacy laws of which may be considered less strict than those of your region.

Marrakesh controls its own copy of information collected through the Marrakesh Site and has an information security program designed to protect information in its possession or control. This is done through a variety of privacy and security policies, processes, and procedures. Marrakesh uses administrative, physical, and technical safeguards that reasonably and appropriately protect the confidentiality, integrity, and availability of the information that it collects, receives, stores, or transmits. Nonetheless, no method of transmission over the Internet, or method of electronic storage, is 100% secure; and therefore, Marrakesh cannot guarantee its absolute security. While Marrakesh works hard to ensure the integrity and security of its network and systems, Marrakesh cannot guarantee that its security measures will prevent “hackers” or other unauthorized persons from illegally accessing or obtaining information.

If Marrakesh learns of a security breach involving its copy of your Personal Information, Marrakesh may attempt to notify you electronically so that you may take appropriate protective steps. By using the Marrakesh Site or providing Personal Information to Marrakesh, you agree that Marrakesh can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Marrakesh Site. If a security systems breach occurs, Marrakesh may post a notice on the Marrakesh homepage (www.marrakeshhaircare.com) or elsewhere on the Marrakesh Site and may send an email to you at the email address associated with your Marrakesh account. Depending on where you are located, you may have a legal right to receive notice of a security breach, involving your Personal Information, in writing.

7. Privacy Policy Updates
This Privacy Policy will be reviewed and updated from time to time. When changes are made, the Privacy Policy will be labeled as “Revised (date),” indicating that you should review the new terms, which will be effective immediately upon posting on this page, with an updated effective date. By accessing the Marrakesh Site after any changes have been made, you accept the modified Privacy Policy and any changes contained therein. In case you miss the notification referenced above, be sure to return to this page periodically to ensure familiarity with the most current version of this Privacy Policy.

8. Contact Information
If you have privacy concerns, have disclosed data you would prefer to keep private, or would like to access the Personal Information that Marrakesh maintains about you, please contact us at [email protected] You may also write to us at: ATTN: PRIVACY, Marrakesh 21900 Plummer Street, Chatsworth, CA 91311.

9. Glossary
Cookies are unique identifiers usually in the form of small data files placed on your device that send certain information about your activity on the Marrakesh Site or in an email communication back to Marrakesh or the authorized third party that served the cookie. Marrakesh or third parties may also use Flash cookies.

Marrakesh Site consists of all content and pages located within the marrakeshaircare.com web domain and all Marrakesh mobile applications.
Subscriber is each person that uses the Marrakesh Site.
Personal Information is information that specifically identifies you or that, when combined with other information, could be used to identify you.
Tracking Technologies are web beacons, clear gifs, pixels, and similar technologies that are also unique identifiers used to track your online activity but are not stored on your device.

Effective Date:
May 23, 2018