Privacy Policy for Sticky Fingers Cooking® and Affiliates

Effective Date: July 1, 2024

Sticky Fingers Cooking® (SFC) and its independently owned and operated affiliates (described in Attachment B) are committed to protecting your privacy. This Privacy Policy explains how we collect, use, and disclose your information when you visit our website, use our services, or interact with us. By using our website and services, you agree to the terms of this Privacy Policy.

Attachment B: Definition of Sticky Fingers Cooking® (SFC) and Independently Owned and Operated Affiliates

Sticky Fingers Cooking® (SFC): Sticky Fingers Cooking® (SFC) refers to the original entity established under the Sticky Fingers Cooking brand. It encompasses the central organization responsible for developing and managing the Sticky Fingers Cooking® program, curriculum, and brand standards. SFC may operate its own cooking classes, events, and programs, as well as provide support and resources to independently owned and operated affiliates.

Independently Owned and Operated Affiliates: Independently owned and operated affiliates of Sticky Fingers Cooking® (SFC) refer to separate legal entities that have entered into franchise agreements or other contractual arrangements with SFC to operate under the Sticky Fingers Cooking brand. These affiliates are owned and operated by individuals or entities independent of SFC and may include cooking schools, camps, community centers, private instructors, or other entities authorized to offer Sticky Fingers Cooking® programs and services.

Each independently owned and operated affiliate is responsible for its own operations, including the management of facilities, staffing, class scheduling, and customer relations. While affiliates may adhere to the overall brand standards and program guidelines set forth by SFC, they operate as separate entities and may have their own policies, procedures, and pricing structures.

Participants should be aware that activities organized by independently owned and operated affiliates may vary in terms of content, format, and quality compared to those directly offered by SFC. However, all affiliates are expected to uphold the core values and principles of the Sticky Fingers Cooking brand, including a commitment to providing engaging, educational, and safe cooking experiences for children.

1. Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy: 

• Account means a unique account created for You to access our Service or parts of our Service.
• Affiliate means an entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest, or other securities entitled to vote for election of directors or other managing authority.
• Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Sticky Fingers Cooking, 3700 Tennyson St #12492 Denver, CO 80212.
• Cookies are small files that are placed on Your computer, mobile device, or any other device by a website, containing the details of Your browsing history on that website among its many uses.
• Country refers to: United States.
• Device means any device that can access the Service such as a computer, a cellphone, or a digital tablet.
• Personal Data is any information that relates to an identified or identifiable individual.
• Service refers to the Website.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Website refers to Sticky Fingers Cooking, accessible from www.stickyfingerscooking.com.
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

2. Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to: 

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

• Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
• Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use both Session and Persistent Cookies for the purposes set out below: 

Necessary / Essential CookiesType: Session Cookies

• Administered by: Us
• Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

Cookies Policy / Notice Acceptance CookiesType: Persistent Cookies

• Administered by: Us
• Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

Functionality CookiesType: Persistent Cookies

• Administered by: Us
• Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

3. Use of Your Personal Data

The Company may use Personal Data for the following purposes:  

• To provide and maintain our Service, including to monitor the usage of our Service.
• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
• To manage Your requests: To attend and manage Your requests to Us.
• For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing, and your experience.

4. Sharing Your Information

We do not sell your personal information. We do not share personal data (phone numbers) and consent with third parties / affiliates or partners.

5. Data Security

Sticky Fingers Cooking (“SFC”) is committed to ensuring the confidentiality, privacy, integrity, and availability of all personal identifiable information (“PII”) it receives, maintains, processes, and/or transmits on behalf of its customers.

The physical infrastructure environment is hosted at Amazon Web Services (“AWS”). The network components and supporting network infrastructure are contained within the AWS infrastructure and managed by AWS. SFC does not have physical access to the network components. The SFC environment consists of security groups, load balancers; nginx web servers; MySQL database servers; and developer tool servers running on Ubuntu Linux.

Within the SFC platform on AWS, all web server data transmission is encrypted, and all databases are encrypted. SFC assumes all data may contain PII. Hosted load balancers segment data within the dedicated Virtual Private Cloud. Additionally, security groups are used on each server for logical segmentation. Security groups are configured to restrict access to only justified ports and protocols. SFC has implemented logical access controls so that only authorized personnel are given access to the internal management servers. The nginx web servers are externally facing and accessible via the Internet. The database servers, where the PII resides, are located within the SFC network. Access to the internal database is restricted to a limited number of personnel and strictly controlled to only those personnel with a business-justified reason. Remote access to internal servers is not accessible except through load balancers unless explicitly allowed through the configuration of the security groups.

6. Your Choices

• Access and Correction: You can access and update your personal information by contacting us.
• Opt-Out: You can opt-out of receiving marketing communications from us by following the unsubscribe instructions provided in the emails.
• Cookies: You can manage cookies through your browser settings.

7. Children's Privacy

Our services are intended for children, but we do not knowingly collect personal information from children under 13 without parental consent. If we become aware that we have collected personal information from a child under 13 without verification of parental consent, we will take steps to delete that information.

8. International Data Transfers

If we transfer data internationally, we will ensure that appropriate safeguards are in place to protect your personal information, in compliance with relevant data protection laws.

9. Rights of Users

Under GDPR:

• ​​​​​​​​​​​​Right to Access: You have the right to request access to the personal data we hold about you.
• Right to Rectification: You have the right to request correction of inaccurate or incomplete data.
• Right to Erasure: You have the right to request the deletion of your data.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to Object: You have the right to object to the processing of your data.

​​​​​Under CCPA:

• Right to Know: You have the right to know what personal information is collected, used, shared, or sold.
• Right to Delete: You have the right to request the deletion of your personal information.
• Right to Opt-Out: You have the right to opt-out of the sale of your personal information.
• Right to Non-Discrimination: You have the right to not be discriminated against for exercising any of your CCPA rights.​​​​​​​

10. Exercising Your Rights

To exercise any of your rights under GDPR or CCPA, please contact us at:

Sticky Fingers Cooking®
3700 Tennyson St #12492, Denver, CO 80212
hello@stickyfingerscooking.com
303-648-4078

We will respond to your request within the timeframes required by applicable law.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on our website. Changes are effective when they are posted on this page.

12. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:

Sticky Fingers Cooking®
3700 Tennyson St #12492, Denver, CO 80212
hello@stickyfingerscooking.com
303-648-4078

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