OUR PRIVACY POLICY

Effective Date: 01-05-2024
We are committed to protecting Your privacy.
This Privacy Policy describes how, we collect, use, store, share and protect
the information collected through http://www.dancewithme-online.com (the
“Website”) and Square Payment (the app) https://squareup.com/gb/en/legal/
general/ua.
In this Privacy Policy, “We”, “Us”, and “Our” refer to Soul Academy/Sabina Lozinschi. For more information about Us, see “Our Details” at the end of this Policy.

This Privacy Policy is incorporated into and subject to Our Terms and
Conditions. Capitalised words used but not defined in this Privacy Policy
have the meaning given to them in the Terms and Conditions.
Please be advised that the practices described in this Privacy Policy apply
only to information gathered online through the Website. This Privacy Policy
applies where we are acting as a data controller with respect to the Personal
Data of visitors, users, clients and customers (“You,” or “Your”); in other
words, where We determine the purposes and means of the processing of
that Personal Data.

PLEASE READ THIS PRIVACY POLICY CAREFULLY because it affects
Your rights under the law. You confirm that You have read and agreed to be
bound by this Privacy Policy. If You do not agree with this Privacy Policy, you
cannot use, access, create or publish in the Website. This Privacy Policy may
change as we continuously improve the Website, so please check it
periodically.

We reserve the right to modify or amend the Privacy Policy from time to time
without notice. Your continued use of the Website following the posting of
1changes to these terms will mean you accept those changes. If we intend to
apply the modifications or amendments to this Privacy Policy retroactively or
to Personal Data already in Our possession, We will provide You with notice
of the modifications or amendments.

CONTENTS
Click below to jump to any section of this privacy policy
1. Your Data
2. Personal Data
1. Data We Collect
2. How We Collect Data
3. Personal Data On Or From Social Media
4. Use of Personal Data
5. Data Security
6. Non-Personal Data
1. Generally, We collect and store the following Non-Personal Data:
7. Use of Non-Personal Data
8. Personal & Non-Personal Data From Other Sources
9. Notifications Data
10.Your Data Privacy Rights
11.Data Protection
12.International Transfer Of The Personal Data of EU Citizens
13.Your Choices
14.Your Right to Access
15.Your Right to Withdraw Consent
16.Your Right to Update, Correct or Delete
17.No Personal Data From Children
18.Cookie Policy
1. Cookie We Use
2. Purpose Of Using Cookies
3. Cookies Used by Our Service Providers
4. Managing Cookies
19.Links To Or From Another Website
20.Public Areas
21.Interest Based Advertising
22.Changes And Updates
23.Assignment
24.Our Details
21. YOUR DATA

Soul Academy / Sabina Lozinschi sole trader strives to provide you with the
best possible service. In order to provide this service we may need to collect
information from you from time to time. At all times we try to only collect the
information we need for the particular function or activity we are carrying out
and use it in accordance with this privacy policy.
We collect two basic types of information from You from Your use of the
Website: Personal Data and Non-Personal Data. Back to table of contents

2. PERSONAL DATA
“Personal Data” means any information relating to an identified or identifiable
natural person; an identifiable natural person is one who can be identified,
directly or indirectly, in particular by reference to an identifier such as a
name, an identification number, location data, an online identifier or to one or
more factors specific to the physical, physiological, genetic, mental,
economic, cultural or social identity of that natural person.
As a general matter, you can browse the Website without submitting Your
Personal Data to Us. However, there are a number of circumstances in which
You may supply Us with Your Personal Data.

2.1 DATA WE COLLECT
We collect the following Personal Data from You:
• Full Name;
• E-mail;
• Phone Number;
• Date of Birth;

2.2 HOW WE COLLECT DATA
The following are the most common ways in which you give Your Personal
Data:
• Participating in communities, chat rooms and comment threads, other
fora, and other interactive services in the Website;
• Submission of User Content on any part of the Website that permit it;
• Any other place in the Website where You knowingly volunteer to give
Personal Data.
• Registration for an Account on the Website;
• Registration for a Subscription;
• Signing up to receive e-mail newsletters or e-mail alerts from Us;
• Requesting for service or other assistance;
• Participating in special events and promotions in the Website;
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3. PERSONAL DATA ON OR FROM SOCIAL MEDIA
When You interact with the Website or Your Account through a social media
platform, such as Facebook, Twitter, Tumblr, LinkedIn, YouTube, or Pinterest,
We may collect the Personal Data that You make available to Us on that
page including Your account ID or handle. We will comply with the privacy
policies of the corresponding social media platform and We will only collect
and store such Personal Data that We are permitted to collect by these
social media platforms. Please do NOT supply any other person’s Personal
Data to Us, unless We prompt You to do so.
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4. USE OF PERSONAL DATA
We do NOT sell or license Your Personal Data to any third party.
We may process any of Your Personal Data identified in this Privacy Policy
where necessary for the establishment, exercise or defence of legal claims,
whether in court proceedings or in an administrative or out-of-court
procedure. The legal basis for this processing is Our legitimate interests,
namely the protection and assertion of Our legal rights, Your legal rights and
the legal rights of others.
In addition to the specific purposes for which We may process Your Personal
Data set out in this clause, We may also process any of Your Personal Data
where such processing is necessary for compliance with a legal obligation to
which We are subject, or in order to protect Your vital interests or the vital
interests of another natural person.
Specifically, we use Your Personal Data for the following:
• responding to Your queries and requests;
• investigating complaints;
• enforcing Our Terms and Conditions;
• as otherwise required or authorised by law or government agency.
• verifying Your identity;
• processing Your requests or instructions;
• creating personalised offers;
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5. DATA SECURITY
We follow generally accepted industry standards to protect the information
submitted to Us, both during transmission and once we receive it. We
maintain appropriate administrative, technical and physical safeguards to
protect Personal Data against accidental or unlawful destruction, accidental
loss, unauthorised alteration, unauthorised disclosure or access, misuse, and
any other unlawful form of processing of the Personal Data in Our
possession. This includes, for example, firewalls, password protection and
other access and authentication controls. We use HTTPS (Hypertext Transfer
Protocol Secure) is an internet communication protocol that protects the
integrity and confidentiality of data between your computer and
www.otimabusedancestudio.com. The use of HTTPS makes sure your
communication with us is:
Encrypted — The data you exchange with us is secure from eavesdroppers.
That means that when you are browsing www.otimabusedancestudio.com,
nobody can track your activities across multiple pages, or steal the data
exchange between your computer and www.otimabusedancestudio.com.
Integral — The use of HTTPS preserves the integrity of data. Your data
cannot be modified or corrupted during transfer.
Authenticated — HTTPS protocol authenticates your communication with us.
This ensures that you are always communicating with our servers.
However, no method of transmission over the Internet, or method of
electronic storage, is 100% secure. We cannot ensure or warrant the security
of any information you transmit to Us or store on the Website, and You do so
at your own risk. We also cannot guarantee that such information may not be
accessed, disclosed, altered, or destroyed by breach of any of Our physical,
technical, or managerial safeguards. If You believe Your Personal Data has
been compromised, please contact Us at office@dancewithme-online.com.
5If We learn of a security systems breach, then we attempt to notify you
electronically so that you can take appropriate protective steps. We may
post a notice through the Website if a security breach occurs.
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6. NON-PERSONAL DATA
Non-Personal Data includes information that does not personally identify
you, but may include tracking and usage information about your location,
demographics, use of the Website and the internet. When You interact with
the Website, We may collect Non-Personal Data and Our servers may
automatically keep an activity log of Your use of the Website.

6.1. GENERALLY, WE COLLECT AND STORE THE FOLLOWING NON-
PERSONAL DATA:
• Demographic information such as age, gender, and five-digit zip code as
part of collecting Personal Data;
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7. USE OF NON-PERSONAL DATA
We may disclose or share Non-Personal Data (or other information, other
than Personal Data) in any other manner that We deem appropriate or
necessary. Among other things, we will disclose Non-Personal Data to third
parties to help Us determine how users use parts of the Website and who
Our users are so We can improve the Website. We will also disclose Non-
Personal Data to Our partners and other third parties about how Our users
collectively use the Website.
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8. PERSONAL & NON-PERSONAL DATA FROM OTHER SOURCES
We may also collect and store information about you that We receive from
other sources to, among other things, enable Us to update and correct the
information contained in our database and to better customise Your
experience on the Website.
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69. NOTIFICATIONS DATA
We may process information that you provide to us for the purpose of
subscribing to Our email notifications and/or newsletters (“Notification
Data“). The Notification Data may be processed for the purposes of sending
You the relevant notifications and/or newsletters. The legal basis for this
processing is consent.
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10. YOUR DATA PRIVACY RIGHTS
If You are a citizen of the EU, we have summarised the rights that you have
under the General Data Protection Regulation (GDPR) in this Section. Some
of the rights are complex, and not all of the details have been included in our
summaries. Accordingly, You should read the relevant laws and guidance
from the regulatory authorities for a full explanation of these rights. Right to
Access. You have the right to confirmation as to whether or not we process
Your Personal Data and, where we do, access to the Personal Data.Data
about You rectified and, taking into account the purposes of the processing,
to have any incomplete Personal Data about You completed.
Right to Erasure. In some circumstances You have the right to the erasure of
Your Personal Data without undue delay. Those circumstances include: the
Personal Data are no longer necessary in relation to the purposes for which
they were collected or otherwise processed; You withdraw consent to
consent-based processing; You object to the processing under certain rules
of applicable data protection law; the processing is for direct marketing
purposes; and the Personal Data have been unlawfully processed.
However, there are exclusions of the right to erasure. The general exclusions
include where processing is necessary: for exercising the right of freedom of
expression and information; for compliance with a legal obligation; or for the
establishment, exercise or defence of legal claims.
Right to Restrict Processing. In some circumstances You have the right to
restrict the processing of Your Personal Data. Those circumstances are: You
contest the accuracy of the Personal Data; processing is unlawful but You
oppose erasure; We no longer need the Personal Data for the purposes of
Our processing, but You require Personal Data for the establishment,
exercise or defence of legal claims; and You have objected to processing,
7pending the verification of that objection. Where processing has been
restricted on this basis, We may continue to store Your Personal Data.
However, We will only otherwise process it: with Your consent; for the
establishment, exercise or defence of legal claims; for the protection of the
rights of another natural or legal person; or for reasons of important public
interest.
Right to Object to Processing. You have the right to object to Our processing
of Your Personal Data on grounds relating to Your particular situation, but
only to the extent that the legal basis for the processing is that the
processing is necessary for: the performance of a task carried out in the
public interest or in the exercise of any official authority vested in Us; or the
purposes of the legitimate interests pursued by Us or by a third party. If You
make such an objection, We will cease to process the Personal Data unless
We can demonstrate compelling legitimate grounds for the processing which
override Your interests, rights and freedoms, or the processing is for the
establishment, exercise or defence of legal claims.
You have the right to object to our processing of Your Personal Data for
direct marketing purposes (including profiling for direct marketing purposes).
If You make such an objection, We will cease to process Your Personal Data
for this purpose.
You have the right to object to Our processing of Your Personal Data for
scientific or historical research purposes or statistical purposes on grounds
relating to Your particular situation, unless the processing is necessary for
the performance of a task carried out for reasons of public interest.
Right to Data Portability. To the extent that the legal basis for Our processing
of Your Personal Data is consent, or that the processing is necessary for the
performance of a contract to which You are party or in order to take steps at
Your request prior to entering into a contract, and such processing is carried
out by automated means, You have the right to receive Your Personal Data
from us in a structured, commonly used and machine-readable format.
However, this right does not apply where it would adversely affect the rights
and freedoms of others.
Right to Complain to a Supervisory Authority. If You consider that Our
processing of Your Personal Data infringes data protection laws, You have a
legal right to lodge a complaint with a supervisory authority responsible for
data protection. You may do so in the EU member state of Your habitual
residence, Your place of work or the place of the alleged infringement.
8Right to Withdraw Consent. To the extent that the legal basis for Our
processing of Your Personal Data is consent, You have the right to withdraw
that consent at any time. Withdrawal will not affect the lawfulness of
processing before the withdrawal.
You may exercise any of Your rights in relation to Your Personal Data through
written notice to Us. See Our Contact Details at the end of this Policy.
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11. DATA PROTECTION
If You are located in the European Economic Area, Your Personal Data will be
processed by Soul Academy / Sabina Lozinschi sole trader. As part of
providing the Website, this Personal Data may be transferred to other
regions, including to Canada and the United States. Such transfers will be
complet Soul Academy/ Sabina Lozinschi sole trader processes Personal
Data in the course of providing the Website, Soul Academy/ Sabina Lozinschi
sole trader will:
• process the Personal Data as a Data Processor, only for the purpose of
providing the Website in accordance with documented instructions from
You (provided that such instructions are commensurate with the
functionalities of the Website), and as may subsequently be agreed to by
You. If Soul Academy/ Sabina Lozinschi sole trader is required by law to
Process the Personal Data for any other purpose, Soul Academy/
Sabina Lozinschi sole trader will provide You with prior notice of this
requirement, unless Soul Academy/ Sabina Lozinschi sole trader is
prohibited by law from providing such notice;
• notify You if, in Soul Academy/ Sabina Lozinschi sole trader opinion,
Your instruction for the processing of Personal Data infringes applicable
Data Protection Legislation;
• notify You promptly, to the extent permitted by law, upon receiving an
inquiry or complaint from You or a Supervisory Authority relating to Soul
Academy/ Sabina Lozinschi sole trader Processing of the Personal Data;
• implement and maintain appropriate technical and organisational
measures to protect the Personal Data against unauthorised or unlawful
processing and against accidental loss, destruction, damage, theft,
alteration or disclosure. These measures shall be appropriate to the
harm which might result from any unauthorised or unlawful processing,
9accidental loss, destruction, damage or theft of Personal Data and
appropriate to the nature of the Personal Data which is to be protected;
• provide You, upon request, with up-to-date attestations, reports or
extracts thereof where available from a source charged with auditing
Soul Academy/ Sabina Lozinschi sole trader data protection practices
(e.g. external auditors, internal audit, data protection auditors), or
suitable certifications, to enable You to assess compliance with the
terms of this Privacy Policy;
• notify You promptly upon becoming aware of and confirming any
accidental, unauthorised, or unlawful processing of, disclosure of, or
access to the Personal Data;
• ensure that its personnel who access the Personal Data are subject to
confidentiality obligations that restrict their ability to disclose the
Personal Data; and upon termination of the Terms, Soul Academy/
Sabina Lozinschi sole trader will promptly initiate its purge process to
delete or anonymise the Personal Data. If You request a copy of such
Personal Data within 60 days of termination, Soul Academy/ Sabina
Lozinschi sole trader will provide You with a copy of such Personal Data.
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12. INTERNATIONAL TRANSFER OF THE PERSONAL DATA OF EU
CITIZENS
In this Section, We provide information about the circumstances in which
Personal Data of citizens of the European Union may be transferred to
countries outside the European Economic Area (EEA).
We have offices and facilities in United Kingdom.The European Commission
has made an “adequacy decision” with respect to the data protection laws of
United Kingdom. Transfers to United Kingdom will be protected by
appropriate safeguards, namely the use of standard data protection clauses
adopted or approved by the European Commission. A copy of the use of
standard protection clauses adopted or approved by the European
Commission can be obtained through: ec.europa.eu
The hosting facilities for Our Website are situated in Netherlands. The
European Commission has made an “adequacy decision” with respect to the
data protection laws of Netherlands. Transfers to Netherlands will be
protected by appropriate safeguards, namely the use of standard data
protection clauses adopted or approved by the European Commission. A
10copy of the use of standard protection clauses adopted or approved by the
European Commission can be obtained through: ec.europa.eu
You acknowledge that Personal Data that You submit for publication through
Our Website or Services may be available, via the internet, around the world.
We cannot prevent the use (or misuse) of such Personal Data by others.
The legal basis for this processing is Our legitimate interests, namely the
proper administration of Our Website and business and communications
with users.
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13. YOUR CHOICES
In general, if You register on the Website, You may update the information
You have provided to Us.
When You register on the Website, You may be able to indicate Your
preferences regarding marketing communications. You may be able to
change those preferences and select the categories of communications that
interest You.
You will not be able to opt-out of receiving certain service-related or
transactional communications relating to the Website unless You cancel Your
registration or subscription.
Even after Your account is cancelled, We may retain Your information for the
purposes set forth in this Privacy Policy.
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14. YOUR RIGHT TO ACCESS
We provide You with reasonable access to the Personal Data that You may
provide through the Website.
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15. YOUR RIGHT TO WITHDRAW CONSENT
At any time, You may legitimately object to the processing of Your Personal
Data, except if otherwise provided by applicable law. You may decline to
share certain Personal Data with Us, in which case We may not be able to
provide to You some of the features and functionality of the Website.
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1116. YOUR RIGHT TO UPDATE, CORRECT OR DELETE
You may update, correct, or delete Your Account Data and preferences at
any time by accessing Your Account settings page on the Website. If You
wish to access or amend any other Personal Data We hold about You, or to
request that We delete any information about You that We have obtained
from an Integrated Service, You may contact Us. Please note that while any
changes You make will be reflected in active user databases instantly or
within a reasonable period of time, We may retain all information You submit
for backups, archiving, prevention of fraud and abuse, analytics, satisfaction
of legal obligations, or where We otherwise reasonably believe that We have
a legitimate reason to do so. We will however retain Your information needed
for administrative and transactional communications.
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17. NO PERSONAL DATA FROM CHILDREN
We do not knowingly collect Personal Data from children under 13 years of
age in the USA or 16 years of age in the European Union. The Website is not
directed to children under the age of 13 in the USA or 16 in the European
Union. We will not knowingly allow children under 13 in the USA or 16 in the
European Union to register for or become users of the Website.
If You are under 13 in the USA or 16 in the European Union years of age, You
should not provide Personal Data to Us.
If We discover that a child under the age of 13 in the USA or 16 in the
European Union has provided Us with Personal Data and We do not have
parental consent, We will immediately delete that child’s information.
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18. COOKIE POLICY
A cookie is a file containing an identifier (a string of letters and numbers) that
is sent by a web server to a web browser and is stored by the browser. The
identifier is then sent back to the server each time the browser requests a
page from the server.
Cookies may be either “persistent” cookies or “session” cookies: a
persistent cookie will be stored by a web browser and will remain valid until
its set expiry date, unless deleted by the user before the expiry date; a
session cookie, on the other hand, will expire at the end of the user session,
when the web browser is closed.
12Cookies do not typically contain any information that personally identifies a
user, but Personal Data that We store about You may be linked to the
information stored in and obtained from cookies.
18.1 COOKIE WE USE
Session Cookies
These are temporary cookies that contain no expiration date and are deleted
after the users browser is closed. You will be required to log in again at the
next session, where you will be treated as a new user
Session cookies examples: Shopping cart, remembering previous actions,
managing and passing security tokens, multimedia content player session
cookies, load balancing session cookies and third party social content plug
in sharing cookies.
Persistent Cookies
These are cookies which are saved in your browser until they are deleted by
the you or are deleted by your browser after they reach their expiration date.
Persistent cookies examples: Authentication, language selection, theme
selection, favourites, internal site bookmarks, menu preferences, address
and payment information.
Functionality Cookies
Functionality cookies allow us to remember choices that have been made by
you in order to create an experience that’s made to fit. These cookies safely
store authentication and identification information, for example your
language selection or region.
Performance Cookies
Performance cookies allow us to collect information, such as the most used
pages or error messages, in order to understand how you use our website
and enable us to create a better user experience. All information collected by
performance cookies in anonymous.
18.2. PURPOSE OF USING COOKIES
Authentication – We use cookies to identify You when You visit Our Website
and as You navigate Our Website;
Status – We use cookies to help Us determine if You are logged into Our
Website;
Personalisation – We use cookies to store information about Your
preferences and to personalise the Website for You;
13Security – We use cookies as an element of the security measures used to
protect user accounts, including preventing fraudulent use of login
credentials, and to protect Our Website and Services generally;
Analysis – We use cookies to help Us to analyse the use and performance of
Our Website and Services;
Cookie Consent – We use cookies to store Your preferences in relation to the
use of cookies more generally.
18.3.COOKIES USED BY OUR SERVICE PROVIDERS
Our service providers use cookies and those cookies may be stored on Your
computer when You visit Our Website.
Google Analytics. We use Google Analytics to analyse the use of Our
Website. Google Analytics gathers information about Website use by means
of cookies. The information gathered relating to Our Website is used to
create reports about the use of Our Website. Google’s privacy policy is
available at: https://www.google.com/policies/privacy/.
18.4 MANAGING COOKIES
You can disable cookie tracking and learn more about the privacy policies of
the third parties We use by visiting the following links:
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19. LINKS TO OR FROM ANOTHER WEBSITE
The Website may contain links to other sites operated by Our affiliates or
third parties. Please be advised that the practices described in this Privacy
Policy do not apply to information gathered through these other sites. We are
not responsible for the actions and privacy policies of third parties and other
sites.
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Third Party Opt Out Page Privacy Policy
Google Analytics Opt Out Privacy Policy
1420. PUBLIC AREAS
Please remember that any information You share in public areas, such as
message boards or feedback sections, becomes public and anyone may
take and use that information. Please be careful about what You disclose
and do not post any Personal Data that You expect to keep private. Please
consult the applicable guidelines, if any, for use of Our chat rooms and other
community areas for more information.
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21. INTEREST BASED ADVERTISING
To help ensure that You receive ads that are relevant to Your interests on the
Website, Our advertisers’ services, and elsewhere on the Internet, We and
third parties (including service providers, advertisers, and advertising
companies) may collect information about Your online activities over time
and across different sites, apps, and devices. We and third parties may use
that information to help understand audience segments. Advertisers may use
the segments to determine the audience groups to which they wish to deliver
particular ads. Through this process, We do not use information that directly
identifies You.
Opt Out. You can opt out of receiving interest-based advertising on Your
computer or laptop from some companies, including Us and Our service
providers.
If You wish to opt out of receiving interest-based advertising on Your mobile
device, please see the advertising preferences information on
support.apple.com for iOS devices or support.google.com for Android
devices.
Opting out does not mean You will no longer receive advertising. It means
that the company or companies from which You opted out will no longer
deliver ads tailored to Your web preferences and usage patterns.
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22. CHANGES AND UPDATES
Please revisit this page periodically to stay aware of any changes to this
Privacy Policy, which We may update from time to time. If We modify the
Privacy Policy, We will make it available through the Website, and indicate
15the date of the latest revision. Any material changes will be posted on this
Website and will come into effect 30 Days after their posting.
In the event that the modifications materially alter Your rights or obligations
hereunder, We will make reasonable efforts to notify You of the change. For
example, We may send a message to Your email address, if We have one on
file, or generate a pop-up or similar notification when You access the
Website for the first time after such material changes are made. If You do not
refuse the changes in writing before they become effective, this shall mean
that You have consented to the Privacy Policy as changed. Your continued
use of the Website after the revised Privacy Policy has become effective
indicates that You have read, understood and agreed to the current version
of the Privacy Policy.
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23. ASSIGNMENT
We may change Our ownership or corporate organisation while providing the
Website and Services. We may also sell certain assets associated with the
Website. As a result, please be aware that in such event, We may transfer
some or all of Your information to a company acquiring all or part of Our
assets or to another company with which We have merged. Under such
circumstances We would, to the extent possible, require the acquiring party
to follow the practices described in this Privacy Policy, as it may be
amended from time to time. Nevertheless, We cannot promise that an
acquiring company or the merged company will have the same privacy
practices or treat your information the same as described in this Privacy
Policy.
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24. OUR DETAILS
If you have questions or concerns regarding this policy or if you need to
make a request please contact us at: office@dancewithme-online.com
16