Privacy Policy

Preamble

This Privacy Policy describes the data protection practices of Titan Global Platforms, Inc. ("Titan Global," "we," "us," or "our"), the company that operates the UnniClass service ("UnniClass"). This Privacy Policy applies to information that we collect and use about you when you access or use the UnniClass website, mobile applications, video streaming platforms, APIs, or other online or mobile services that link to or otherwise present this Privacy Policy to you (collectively, the "Services").

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.

This Privacy Policy applies to all users globally, including visitors who are simply browsing our course catalog as well as registered members of UnniClass. If you are a resident of California, this Policy incorporates the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA/CPRA"); if you reside in the European Economic Area ("EEA"), Switzerland, or the United Kingdom, this Policy incorporates the requirements of the UK and EU General Data Protection Regulation ("GDPR"). For users outside these regions, we apply a unified global privacy standard consistent with applicable local laws and South Korea's Personal Information Protection Act ("PIPA") regarding cross-border data transfers.

1. Definitions

Capitalized terms used but not defined in this Privacy Policy shall have the same meanings ascribed to them in our Terms of Service ("Terms").

2. Personal Data We Collect

We collect information about you through various means discussed below. Please note that we need certain types of information so that we can provide the Services to you. If you do not provide us with such information, or ask us to delete it, you may no longer be able to access or use our Services. All data listed in this section is subject to collection, recording, structuring, storage, encryption, pseudonymization, erasure, and transmission.

2.1 Information You Provide Directly to Us

Service Category	Items Collected (Examples)	Legal Basis
Account Data	Email address, password, account settings, name, preferred language, country, occupation, and skill interests.	Contract Performance / Legitimate Interests
Learning Data	Enrolled/completed courses, assignments, quizzes, completion certificates, digital badges, exchanges with instructors/students, and Q&A submissions.	Contract Performance / Legitimate Interests
Student Payment Data	Billing address, ZIP code, card brand, last 4 digits, expiration date, and refund history. Full card numbers are processed directly by a secure payment gateway (Stripe) and are never stored on our servers.	Contract Performance / Legal Obligation
Instructor Payment Data	Payment email address, account ID, physical address, tax identification numbers (W-8BEN equivalents), and payout details via PayPal or Payoneer, collected under our individual instructor agreements.	Contract Performance / Legal Obligation
Applications & Screening	Resumes, written responses, portfolio links, and video submissions for special cohorts or instructor screening.	Contract Performance / Legitimate Interests
Information About Others	If purchasing a gift subscription or card for someone else, the recipient's name and email/shipping address solely to deliver the gift.	Contract Performance

2.2 Automated Collection & Email Analytics

System & Usage Data: IP address, device type, operating system version, unique device identifiers, browser type/language, referring/exit URLs, click data, pages viewed, time spent, search queries, error logs, and approximate location (city/country).

Email Analytics (Clear GIFs & Web Beacons): Emails sent by us may contain web beacons or tracking pixels to record delivery, open rates, and link clicks to measure campaign effectiveness.

2.3 Social Media, Third Parties & Sensitive Data Handling

Social Media Connections: Logging in via social networks (Google, Apple, Meta, Twitter) allows us to receive profile data (name, email, profile picture) controlled by your privacy settings on those platforms.

Data Enrichment Sources: We may receive business contact details or demographic information from trusted commercial sources and analytics partners to enrich our records and personalize your experience.

Non-Collection of Sensitive Personal Data: We do not knowingly collect Sensitive Personal Data (e.g., social security numbers, government ID numbers, racial origin, political opinions, health data, or biometric identifiers). Please do not submit such data to us.

2.4 Children's Privacy

Our Services are intended for users who meet the minimum age requirement set out in our Terms of Service (currently 18 years of age) and are not directed to children. We do not knowingly collect Personal Data from anyone under that minimum age. If we become aware that we have inadvertently collected Personal Data from someone under the minimum age, we will delete it promptly. A parent or guardian who believes we may have collected such information may contact us at admin@unniclass.com.

3. How We Use Your Data & Generative AI Policy

Service Provision & Transactions: Facilitating course streaming, issuing completion certificates, processing payments, delivering gift cards, and managing instructor payouts.

Communication & Support: Responding to support inquiries, resolving billing issues, and sending transactional updates.

Marketing & Targeted Advertising: Sending promotional offers via email, delivering personalized content, and sharing hashed, non-human-readable email tokens with ad networks for custom audience targeting.

AI & Machine Learning Commitment: We do NOT use your Personal Data, User Content, homework, or Q&A submissions to train, retrain, or fine-tune any public or internal Generative AI (GenAI) or machine learning model without your additional, explicit consent.

Legal Compliance & Security: Preventing fraud, detecting unauthorized screen recording or account sharing, and enforcing our Terms.

4. Who We Share Your Data With

4.1 Strict Student-Instructor Data Isolation Policy

We share certain engagement data with course instructors (such as your country, browser language, course enrollment, and review content) to help them improve their course quality. However, we NEVER share a student's actual email address with instructors or teaching assistants.

4.2 Service Providers (Processors)

Service Provider	Shared Data	Business Purpose	Location	Protection Safeguards
Amazon Web Services (AWS)	All platform data, VOD logs	Cloud hosting & infrastructure	USA / S. Korea	Encryption & Contractual Terms
Stripe	Billing details, transaction logs	Credit card & global payment processing	USA / Global	PCI-DSS Level 1 Compliant
Mailchimp / Klaviyo	Name, email, course engagement	Marketing automation, transactional emails	USA	Standard Contractual Clauses (SCCs)
Google Analytics & Meta	Device IDs, IP address, usage logs	Platform analytics, targeted advertising	USA	Privacy Frameworks & Opt-out

4.3 Public Forums, Testimonials & UGC

Comments, reviews, and forum posts you submit are publicly viewable. These submissions are non-confidential, may be indexed by search engines, and may be used by us in marketing testimonials.

4.4 Corporate Transfers & Legal Compliance

Legal Demands: Disclosures required by subpoenas or court orders. Notice will be provided unless legally prohibited or where notice would create a risk of fraud or obstruction of justice.

Business Restructuring: In M&A, asset sales, or insolvency—including during due diligence/contemplation phases—data may be transferred as a business asset subject to prior notification.

5. Email Communications & Cookies

5.1 Email as Our Primary Communication Channel

Titan Global is based in the United States and communicates with you primarily through the email address associated with your account, which serves as our core contact database for both transactional messages (receipts, course access, policy notices) and promotional messages. You may unsubscribe from promotional emails at any time; transactional/administrative emails will continue regardless (see Section 6.3). We do not currently send marketing SMS, MMS, or automated phone calls.

5.2 Cookie Management & Ad Network Opt-Outs

We use Strictly Necessary, Functional, Performance, Advertising, and Social Media cookies. You may manage cookies via browser settings or opt out of targeted advertising via the Network Advertising Initiative (NAI), Digital Advertising Alliance (DAA), or Google Ads Settings.

5.3 Global Privacy Control (GPC)

We process legally mandated Global Privacy Control (GPC) opt-out preference signals for targeted advertising.

6. Your Rights and Choices

6.1 Access, Correct, Delete & Restrict

You may access, update, or request erasure or temporary suspension of processing of your Personal Data.

6.2 Opting Out of Profiling

You have the right to opt out of automated profiling that produces legal or similarly significant effects.

6.3 Marketing Emails vs. Administrative Notices

Unsubscribing from promotional emails stops marketing messages, but you will continue to receive transactional/administrative emails (receipts, policy updates, security alerts).

6.4 Post-Termination UGC Retention

Even after your account is deleted, certain content you shared publicly (comments, forum posts) may remain visible if copied, shared by others, or posted to third-party platforms.

6.5 Requests & Appeals

Submit privacy requests to admin@unniclass.com. We target a response within 30 days, and in all cases will respond within the timeframe required by applicable law, which may be longer (for example, up to 2 months under GDPR for complex requests, or up to 45–90 days under certain US state laws as described in Section 10.2). Where a right to appeal a denied request applies under applicable law, you may appeal our decision by emailing admin@unniclass.com within the timeframe specified in the applicable law or, absent a specific statutory period, within thirty (30) days.

7. Security Safeguards & Limitations

We implement administrative, technical, and physical security measures—including TLS 1.3 encryption in transit, AES-256 encryption at rest, and Multi-Factor Authentication (MFA). However, no system is 100% secure. You acknowledge the security limitations of the Internet and are responsible for protecting your account credentials.

Data Breach Protocols: Confirmed security breaches will be investigated promptly, reported to relevant authorities, and notified to affected users via email and platform announcements.

8. Data Retention Criteria

We retain Personal Data based on: The duration of our active business relationship with you; User modifications or deletion requests submitted via settings; Statutory retention mandates under South Korea's e-commerce consumer protection regulations (which generally require retention of contract/withdrawal records, payment records, and delivery records for up to 5 years), and separately, tax and accounting laws that may require longer retention of financial records; or Legitimate legal positioning, dispute resolution, and managing statutes of limitations.

9. European Data Protection Specific Information (GDPR)

EEA, Swiss, and UK residents possess rights under GDPR Art. 15–22. Contact admin@unniclass.com to exercise rights or lodge a complaint with a supervisory authority.

9.1 Legal Bases for Processing (GDPR Art. 6)

Processing Activity	Legal Basis (GDPR Art. 6)	Notes
Account Registration & Identity Verification	Art. 6(1)(b) — Contract Performance	Essential to perform Terms of Service.
Order Fulfillment & VOD Streaming	Art. 6(1)(b) — Contract Performance	Essential to deliver purchased courses.
Promotional Email Campaigns	Art. 6(1)(a) — Consent	Consent withdrawable at any time.
Targeted Advertising & Retargeting	Art. 6(1)(a) — Consent (EEA/UK)	Managed via Cookie Banner preferences.
Fraud Prevention & Platform Security	Art. 6(1)(f) / Art. 6(1)(c)	Overriding legitimate interest to protect IP.
Tax & Statutory Accounting	Art. 6(1)(c) — Legal Obligation	Statutory transaction record preservation.

10. US State Privacy Policy Addendum

10.1 California Notice at Collection (CCPA/CPRA)

We collect 10 categories of personal info (Credentials, Identifiers, Demographics, Transactions, Device IDs, System info, Internet Activity, Location, Payment info, Content). We do not knowingly collect Sensitive Personal Information as defined under CPRA.

Targeted Ad Opt-Out & Financial Incentives: Sharing data for targeted ads may constitute a "sale/sharing" under state laws (Opt-out via Cookie Preferences or GPC). Promotional discount coupons offered for newsletter signups constitute financial incentives under CCPA.

10.2 Rights Across US States with Comprehensive Privacy Laws

Residents of California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia, and any other state with a comprehensive consumer privacy law in effect, may exercise the rights granted under their state's law, which may include access, correction, deletion, and data portability. The specific rights available, and whether a right to appeal a denied request applies, vary by state — for example, certain states' laws do not provide a right to correction, a right to opt out of profiling, or a right to appeal. Requests may be submitted to admin@unniclass.com. We target a response within 30 days, and in all cases will respond within the timeframe required by applicable state law (which may be up to 45 days, extendable by an additional 45 days where permitted, or up to 90 days under certain states' laws such as Iowa's).

10.3 Identity Verification & Authorized Agents

Before completing an access, correction, deletion, or portability request, we will take reasonable steps to verify the requester's identity, typically by matching the request to the email address and other information already associated with the account, or through additional verification steps where required by law. Consumers may designate an authorized agent to submit a request on their behalf; we may require proof of the agent's authorization and separately verify the consumer's identity before honoring the request.

10.4 California "Shine the Light"

California residents may request, once per calendar year and free of charge, disclosure of the categories of personal information we shared with third parties for those third parties' own direct marketing purposes during the preceding calendar year, along with the names of those third parties. Submit such requests to admin@unniclass.com. As described in Section 4.2, our current service providers process your data on our behalf and do not use it for their own independent direct marketing purposes; if this changes, we will identify the specific recipients in our response to your request.

11. International Transfers & Cross-Border Safeguards

Titan Global is headquartered in the United States, with cloud infrastructure (AWS) located in the United States and operational staff in the Republic of Korea. Personal data may be transferred, stored, and processed internationally.

We implement legal cross-border safeguards, including Standard Contractual Clauses (SCCs) approved by the European Commission, and adherence to South Korea's Personal Information Protection Act (PIPA) Article 28-8 regarding cross-border transfers.

Dispute Resolution Mechanism: Unresolved privacy complaints from EU/UK/Swiss users may be submitted to admin@unniclass.com, and, where applicable, referred to the competent local data protection supervisory authority.

12. Changes & Language Interpretation Control

We reserve the right to amend this Privacy Policy at any time. Material changes will be notified via email or platform notice prior to the effective date. Without your explicit consent, we will not use your Personal Data in a manner materially different from what was stated at the time of collection.

Governing Language: Any version of this Privacy Policy provided in a language other than English is provided for convenience only. In the event of any conflict or inconsistency between a non-English version and the English version, the English version shall control and govern.

13. How to Contact Us & DPO

Company Name: Titan Global Platforms, Inc. (operator of the UnniClass service), a Delaware C Corporation

Delaware File Number: 10751483

Address: 2810 North Church Street, Wilmington, DE 19802, United States

General Privacy Inquiries E-mail: admin@unniclass.com

Designated Data Protection Officer (DPO / Privacy Team)

If you have any questions or requests regarding your personal information or this Privacy Policy, please contact our Data Protection Officer at:

Name: Jungwoo Choi
Title: Data Protection Officer (or Privacy Team)
Address: c/o Titan Global Platforms, Inc., 2810 North Church Street, Wilmington, DE 19802, United States
E-mail: admin@unniclass.com

EU/UK Representative: Where required under Article 27 of the GDPR or the UK GDPR, Titan Global will appoint a representative established in the EEA and/or the UK, and will publish that representative's name and contact details in this Section. Until such an appointment is made, EEA and UK data subjects may exercise their rights and raise any GDPR/UK GDPR-related matter directly with us at admin@unniclass.com, and we will respond as the data controller.