Last updated October 30, 2024

Thank you for choosing to be part of our community at LIVE, by Po-Shen Loh, Daily Challenge with Po-Shen Loh, and The Game, all of which are provided by Expii, Inc. (“Company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at privacy@expii.com.

When you visit any of our websites under the domain poshenloh.com (with any subdomain, including but not limited to live.poshenloh.com, daily.poshenloh.com, game.poshenloh.com, and forum.poshenloh.com) or under the subdomain expii.onlinetests.app, and use our services, or join a video meeting (e.g., Zoom) hosted by us, you trust us with your personal information. We take your privacy very seriously. This Privacy Policy (“Policy”) explains our policies regarding the personal information and other information we collect, how we use it and what rights and choices you have regarding personal information subject to the Policy. Please read through it carefully, as it is important. If there are any terms in this Policy that you do not agree with, do not use our Sites and our services.

This Policy applies to all information collected through our website(s) where we link to the Policy (such as live.poshenloh.com, daily.poshenloh.com, game.poshenloh.com, and forum.poshenloh.com), and our related services, video meetings, sales, marketing or events (collectively, the "Sites") where another policy does not apply. 

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE USE YOUR INFORMATION?
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
4. WHO WILL YOUR INFORMATION BE SHARED WITH?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. DO WE USE GOOGLE MAPS?
7. HOW LONG DO WE KEEP YOUR INFORMATION?
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
9. WHAT ARE YOUR PRIVACY RIGHTS AND CHOICES?
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
12. WHERE DO WE PROCESS YOUR INFORMATION?
13. DO THE SITES CONTAIN OTHER LINKS?
14. DO WE MAKE UPDATES TO THIS POLICY?
15. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In short: We collect personal information that you provide to us such as name, address, self-reported location information, contact information, passwords and security data, and payment information, as well as any other information you disclose on our Sites (including but not limited to chat messages, posts, status messages, and profile pictures).

“Personal information” means information by which a person can be specifically identified. We collect personal information that you voluntarily provide to us when you register at the Sites, contact us to obtain information about us or our products and services, participate in activities on the Sites (such as posting messages in our online forums, sending private messages, sending audio, video, or text in video meetings, or entering competitions, contests or giveaways) or otherwise interact with us.

The personal information that we collect depends on the context of your interactions with us and the Sites, the choices you make and the products and features you use. The personal information and other information we collect can include the following:

• Name and contact data. We collect your first and last name, email address, postal address, phone number, and other similar contact data. We also collect a parent’s email address and other similar contact data for a parent.
• Voluntarily-reported location information. We allow you to self-report your approximate location, if you choose to do so.
• Credentials. We collect passwords and similar security information used for authentication and account access.
• Audio/video and session content. We collect information during class sessions, webinars and other services we provide. This information includes audio, video, chat messages, files and other related content. If you consent to participate in a recorded meeting, you consent to the collection of this information, including your voice and image and video of you if you elect to use audio and camera features. We also collect your profile content that you create (such as a profile picture) for any software services that we use to provide our services.
• Payment data. We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by our payment processors and the information you submit is subject to the appropriate processor’s privacy policy located on its website at https://stripe.com/privacy or https://www.paypal.com/us/legalhub/privacy-full. You should review this privacy policy before submitting any payment information, and contact the payment processor directly to respond to your questions regarding its privacy practices.
• Service providers. We collect personal information of individuals associated with service providers that we engage to provide services to us.
• Activities visible to some or all other users.We may offer you opportunities to engage in interactions with our employees and/or some or all other users on the Sites (“Public Activities”). Public Activities are any actions that you take on the Sites that are designed to be visible to some or all other users of the Sites, whether you are interacting with our employees or other users, such as asking questions or making comments in a chat function. Any information that you disclose in your Public Activities, along with your screen name or ID and any image or photo you post, is collected by us and also becomes public. If you choose to engage in Public Activities, you should be aware that any personal information that you submit can be read, collected, used or published elsewhere by other users of the Sites. For more information, see our Terms of Use.

All information that you provide to us must be true, complete and accurate, and you must notify us of any changes to your information. You are not obligated to provide us with your personal information in all of the cases described above or to browse some portions of our website. However, without your personal information, we may not be able to fulfill all of the functions described above. For example, we will not be able to enroll you in a course.

Personal information of minors

In short: We do not knowingly collect personal information from children under 13 years of age without parental or guardian consent.

We collect personal information of children under 13 years of age pursuant to the terms of our COPPA Privacy Policy with parental or guardian consent. If you believe that we might have collected any personal information from a child under age 13 without parental or guardian consent, please contact us using the details provided in Section 15 below.

Information automatically collected

In short: Some information — such as IP address and/or browser and device characteristics — is collected automatically when you visit our Sites.

We automatically collect certain information when you visit, use or navigate the Sites. This information may include device and usage information, such as your IP address, browser and device characteristics; operating system; language preferences; referring URLs; device name; country; location; information about how and when you use our Sites and other technical information. This information is primarily needed to maintain the security and operation of our Sites, and for our internal analytics and reporting purposes.

We also collect information through cookies and similar technologies as described below.

Information collected from other sources

In short: We may collect limited data from public databases, marketing partners, and other outside sources.

We may obtain personal and other information about you from other sources, such as public databases and joint marketing partners, as well as from other third parties. Examples of the information we receive from other sources include: social media profile information; marketing leads; and search results and links, including paid listings (such as sponsored links).  We may link this information to other personal information we have collected about you.

2. HOW DO WE USE YOUR INFORMATION?

In short: We process your personal and other information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Sites for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

• To send administrative information to you. We may use your information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
• Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Sites.
• To send you marketing and promotional communications. We may use your information for our marketing purposes. You can opt-out of our marketing emails at any time (see “WHAT ARE YOUR PRIVACY RIGHTS AND CHOICES” below).
• Provide our services to other users. Recorded sessions (which may contain your voice, image and video content if you elect to use those features) and your Public Activities may be shared with other users of the Sites.
• Administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in competitions.
• Request feedback. We may use your information to request feedback and to contact you about your use of our Sites.
• To protect our Sites. We may use your information as part of our efforts to keep our Sites safe and secure (for example, for fraud monitoring and prevention, or for chat moderation to detect improper behavior).
• To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user's consent.
• To engage with you in a public forum or private chat. We may use your information to interact with you and other users through public forums or private chats that may be offered on the Sites, such as through a chat function. For example, we may send your chat messages to human or artificial intelligence agents, and they may provide useful replies to you.
• To enforce our terms, conditions, and policies.
• To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to use your information to determine how to respond and to respond.
• For other business purposes. We may use your information for other business purposes, such as evaluating our instructors (for example, by reviewing recorded sessions and the instructor’s interactions with you), data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Sites, products, services, marketing and your experience.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In short: We share your personal and other information with your consent, to comply with laws, to protect your rights, to fulfill business obligations, and for our business purposes.

We may disclose or share your personal information based on the following legal bases:

• Consent. We may process your information if you have given us consent. Without limiting the foregoing, if you choose to engage in a recorded session and/or conduct Public Activities, you consent to the disclosure of the recorded session, which may contain your voice, image and video content if you elect to use those features, and your Public Activities to us and any other users of the Sites.
• Legitimate interests. We may process your information when it is reasonably necessary to achieve our legitimate business interests.
• Performance of a contract. Where we have entered into a contract with you, we may process your information to fulfill the terms of and administer our contract.
• Performance of a service. We provide various services on our Sites. For some of them, we may share your information with third party service providers which assist in providing the services. For example, your chat messages may be processed by human or artificial intelligence agents from third party service providers.
• Legal obligations. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital interests. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

4. WHO WILL YOUR INFORMATION BE SHARED WITH?

In short: We share your personal and other information with third parties as described in this Policy.

We may share your personal information with third parties in the following situations:

• Vendors, consultants, contractors, and other third-party service providers. We may share your information with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, human or artificial intelligence services, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Sites, which will enable them to collect data about how you interact with the Sites over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. These third parties are required to protect your data and may only use it as instructed by us. We do not sell or share your data for marketing purposes without your explicit consent.
• Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
• Other users. Recorded sessions, which may contain your voice, image and video content if you elect to use those features, and your Public Activities may be shared with other users of the Sites, such as other course participants.  Other users of the Sites will be able to view descriptions of your activity, communicate with you within our Sites, and view your profile.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In short: We may use cookies and other tracking technologies to collect and store your information.

When you visit the Sites, we may place, or authorize third parties to place, cookies and similar tracking technologies (like web beacons and pixels) on your device to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

6. DO WE USE GOOGLE MAPS?

In short: Yes, we use Google Maps for the purpose of providing better service.

Parts of our Sites use Google Maps APIs. You may find the Google Maps APIs Terms of Service here. To better understand Google’s Privacy Policy, please refer to this link.

By using our Maps API Implementation, you agree to be bound by Google’s Terms of Service. If you voluntarily report your approximate location in our service, you agree to allow us to display it to other users. You may revoke your consent at any time by changing your voluntarily reported approximate location to a blank value. We use information about location in conjunction with data from other data providers.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In short: We keep your information for as long as necessary to fulfill the purposes outlined in this Policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). With the exception of legal and compliance purposes, we generally will not retain personal information longer than 1 year past the termination of the user's account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not feasible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it to the extent feasible from any further processing (except for legal and compliance purposes) until deletion is possible.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites is at your own risk. You should only access the services within a secure environment.

9. WHAT ARE YOUR PRIVACY RIGHTS AND CHOICES?

In short: You may review, change, or terminate your account at any time and exercise choices to opt-out of certain processing of your personal information.

Account information. If you would at any time like to review or change the information in your account or terminate your account, you can log into your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases in accordance with our retention period described above. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use, for compliance purposes and/or comply with legal requirements.

Cookies and similar technologies. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Sites. We use Google Analytics to analyze usage of the Sites. You can review how Google uses this information and how you can control information collected by Google Analytics by visiting https://policies.google.com/technologies/partner-sites.

Opting out of email marketing. You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided in Section 15 below. You will then be removed from the marketing email list; however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out of our using your personal information for our marketing purposes, you may contact us using the details provided in Section 15 below.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Policy.

11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes in the immediately preceding calendar year and the names and addresses of such third parties. Alternatively, we may provide a right to opt-out of such sharing. This Policy provides an opt-out mechanism.

If you are under 18 years of age, reside in California, and have a registered account with the Sites, you have the right to request removal of unwanted data that you publicly post on the Sites. To request removal of such data, please contact us using the contact information provided in Section 15 below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Sites, but please be aware that the data may not be completely or comprehensively removed from our systems and we cannot control if the data has already been copied, reposted and/or made public by others.

12. WHERE DO WE PROCESS YOUR INFORMATION?

In short: Expii, Inc. is a United States company.

Any information we collect, including personal information you provide to us, may be transferred to and processed in the U.S. If you are located outside the U.S., please be advised that the U.S. does not offer safeguards to protect personal information that are as stringent as some other jurisdictions in the world. For example, the European Union does not consider U.S. privacy safeguards to be adequate to protect personal information. Our service providers may process information in other locations throughout the world.

13. DO THE SITES CONTAIN OTHER LINKS?

In short: We are not responsible for other websites.

The Sites may contain links to other websites. We are not responsible for the information collection or privacy practices of other websites. You should consult the privacy policies of other sites before you visit those sites or provide any information to those sites. We do not control the privacy practices of such third-party sites.

14. DO WE MAKE UPDATES TO THIS POLICY?

In short: Yes, we will update this policy as necessary to stay compliant with relevant laws or reflect updates to our business practices.

We may update this Policy from time-to-time. The updated version will be indicated by the “Last updated” date and the updated version will be effective as soon as it is accessible. If we make material changes to this Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Policy frequently to be informed of how we use your information and your choices.

15. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this Policy, or want to exercise any of your rights and choices described above, you may email us at privacy@expii.com or write to us by post to:

Expii, Inc.
260 Atwood Street
Pittsburgh, PA 15213