1. Scope & Applicability

This Privacy Policy governs personal data collected directly through Palinode Productions LLC, when used by individuals age 13 and older. These Terms are an agreement between you and Palinode Productions LLC. References to “us”, “we”, “our”, and “Palinode” shall mean Palinode Productions LLC. This policy applies when we act as a data controller, i.e., offering services directly to users. It does not apply when we act as a processor for an institution—you would be governed by that institution’s privacy policy.

This policy applies to all content hosted on the palinode.org and khora.world domains.

2. Information We Collect

We collect only the following personally identifiable information directly from you:

• Name or Alias

• Email Address

Additionally, we may use Google Analytics by Google LLC to analyze website usage and to collect the following information:

• IP address

• Device type (desktop, mobile, tablet)

• Operating system (Windows, iOS, Android, etc.)

• Browser and browser version

• Screen resolution

• Language and country/region (derived from IP address)

• Approximate location (city/region level, not precise address)

• Usage/interaction data

• Cookies or similar identifiers

We do not collect payment details or location data.

3. Purpose & Legal Basis for Processing

We process your personal information, specifically your name or alias and email address, to create and manage your account, communicate with you about platform-related updates or support, and perform internal analytics to enhance educational outcomes and user experience. The purpose of collecting information using Google Analytics is to perform website analytics, measure website performance, identify areas of website improvement, and perform marketing analysis. Our legal basis for this processing is your consent, as provided during registration, and our legitimate interest in improving the platform, including under Art. 6(1)(a) of the GDPR. We do not sell your data under any circumstances.

4. Data Sharing & Disclosures

We may share aggregated, pseudonymized, or anonymized data with trusted third-party service providers for internal analytics and to improve user experience and learning outcomes. We do not disclose your name or email address to third parties, and we do not sell or rent your data. Google LLC may process data on our behalf, and data may be transferred from the EU to the United States.

5. Data Retention

Your information is stored indefinitely unless you explicitly request deletion or correction. We retain data to:

• Track learning progress,

• Maintain continuity of user experience,

• Comply with potential legal obligations.
  
  

6. International Data Transfer & Security

Data may be stored or processed outside the EU or U.S. We implement Standard Contractual Clauses, EU–U.S. Data Privacy Framework mechanisms, and other legal safeguards to ensure secure international transfers. We employ a variety of physical, technical, and organizational security measures, such as encryption, access control, periodic reviews, and secure hosting, to protect your personal data.

7. Tracking and Cookies

We use functional and security-related first-party cookies to ensure proper operation of our systems as you access them. We may also use analytics-related cookies if you explicitly consent via the provided cookie banner. Analytics-related cookies are used to improve our understanding of website usage. We do not collect location data.

8. Children’s Privacy

Our service is intended for individuals aged 13 or older. We do not knowingly collect personal information from children under 13. If you believe a minor has provided us data, contact us immediately.

9. Your Rights Under GDPR & CCPA

You have the following rights:

• Access – obtain a copy of your personal data

• Correction – rectify inaccurate or incomplete data

• Deletion (“Right to be forgotten”) – erasure of your data

• Restriction – limit how we use or process your data

• Object – opt out of specific processing (e.g., analytics)

• Portability – receive your data in a machine-readable format

• Non-discrimination – exercise of your rights does not lead to denial of services

To exercise any of these rights, contact us at palinodeproductions@gmail.com. Under GDPR, some requests may be limited if we have overriding legal, regulatory, or contractual obligations. You also have the right to lodge complaints with the relevant Data Protection Authority—in the EU or with the California Attorney General—if you believe your rights are violated.

10. Changes to This Policy

We may update this Privacy Policy to reflect changes in law, service, or our data practices. Material changes will be communicated via email and posted on our Platform with a clear “Last Updated” date.

11. Contact Us

If you have questions, need help exercising your privacy rights, or wish to request changes to your data, please contact: palinodeproductions@gmail.com

Global Privacy Officer Palinode Productions LLC P.O. Box 30016 Spokane, WA 99223 United States