IMPORTANT: This Policy constitutes a legally binding agreement between you (“User”, “you”, “your”) and Dancefolio (hereinafter referred to as “Owner”, “Website”, “we”, “us”, or “our”). This document governs the privacy of your Personal Information while using the website dancefolio.org and its related services.
1. INTRODUCTION AND ACCEPTANCE
We respect your privacy and are committed to protecting it through our compliance with this privacy policy (“Policy”). This Policy describes the types of information we may collect from you or that you may provide (“Personal Information”) on the Dancefolio website (“Website”) and any of its related products and services (collectively, “Services”), and our practices for collecting, using, maintaining, protecting, and disclosing that Personal Information.
1.2 Relationship with Terms of Service This Privacy Policy works in conjunction with our Terms of Service. These two documents do not exclude each other but are intended to be read and applied together to govern your use of the Services.
- Joint Acceptance: By accessing or using the Services, you acknowledge that you have read, understood, and agree to be bound by BOTH this Privacy Policy and our Terms of Service.
- Mandatory Discontinuation: If you do not agree with the terms of either this Privacy Policy or the Terms of Service, you are strictly prohibited from accessing the Website. You must immediately discontinue all use of the Services and delete your account.
1.3 Scope This Policy applies to information we collect:
- On this Website.
- In email, text, and other electronic messages between you and this Website.
- Through interactions with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Policy.
2. DATA CONTROLLER
Under the GDPR, our role in handling your Personal Information changes depending on the specific context:
- As a Data Controller: We act as a Data Controller when we collect information necessary to create your account and grant you access to our Services. In these instances, we determine the purposes and means of processing your data to deliver the Services to you.
- As a Data Processor: We act as a Data Processor when you submit Personal Information through the Services (such as uploading a resume or profile data) for us to process on your behalf. In this capacity, we do not own or control the data; we strictly process it according to your instructions.
Note for Users in the USA and Canada: To the extent that the California Consumer Privacy Act (CCPA) applies, the term “Data Controller” shall be interpreted as “Business” and “Data Processor” as “Service Provider.” Under Canadian laws (PIPEDA), we remain accountable for personal information under our control and use third-party service providers only in accordance with applicable privacy standards.
Requirement to Provide Information: We collect certain Personal Information solely to meet legal obligations or to make the Services available to you. Failure to provide this mandatory information may prevent us from delivering the requested products or Services.
Owner and Data Controller Contact Email: info@dancefolio.org.
Sole Proprietorship: You acknowledge that Dancefolio is not a Limited Liability Company (LLC) or Corporation. While we adhere to strict data protection standards, you agree that any liability is limited to the extent permissible by applicable law regarding sole proprietorships.
3. DEFINITIONS
- “Personal Data” (or “Personal Information”): Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
- “Usage Data”: Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
- “User”: The individual using this Website who, unless otherwise specified, coincides with the Data Subject.
- “Data Subject”: The natural person to whom the Personal Data refers.
- “Data Processor” (or “Data Supervisor”): The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller.
4. TYPES OF DATA COLLECTED
We collect several types of information from and about users of our Services, including:
4.1 Information You Provide to Us include:
- Registration Data: First name, last name, email address, username, password, and user role (e.g., Dancer, Teacher, Company).
- Profile Information: Date of birth, physical address, city, state, country, ZIP/postal code, gender, ethnicity, height, current academic grade, and professional biography.
- Professional Data: Resumes (CVs), headshots, pose shots, dance reels, video links, portfolios, and details of dance experience/qualifications.
- User Generated Content (UGC): Articles, images, feedback, comments, reviews, forum posts, and messages sent via Messages.
- Payment Information: Credit card details, billing address, and transaction history. Note: Full credit card numbers are processed by our payment processors (Stripe) and are not stored on our servers.
- Answers and Feedback: Responses to polls (via Poll plugin), surveys, or forms (Fluent Forms).
4.2 Information Collected Automatically
- Device and Connection Information: IP address, browser type and version, operating system, language preferences, time zone setting, and browser plug-in types.
- Interaction Data: Mouse movements, scroll position, clicks, touch events, and keypress events (collected via Google reCAPTCHA and analytics tools).
- Geolocation Data: We collect non-continuous geolocation data (latitude/longitude) to provide location-based services via HivePress Geolocation and external services such as Mapbox and Google Maps. This occurs when you search for listings near you or permit the browser to share your location.
4.3 Special Categories of Data We do not knowingly request sensitive personal information (racial/ethnic origin, political opinions, religious beliefs, health data) unless you voluntarily include it in your profile bio or resume. If provided, you consent to its processing as part of your profile.
5. METHODS OF PROCESSING
5.1 Security Protocols The Data processing is carried out using computers and/or IT-enabled tools, following organizational procedures and modes strictly related to the purposes indicated. We utilize plugins and softwares to monitor for malware, audit logs, and harden the website against unauthorized access. This is to ensure the safety of the website and its users.
5.2 Access to Data In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The information will still be collected by Dancefolio and will be exclusively used for the purposes specified in this agreement.
5.3 Place of Processing The Data is processed at the Owner’s operating offices in Italy and in any other places where the parties involved in the processing are located. Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own (e.g., servers in the USA via GoDaddy or Automattic).
5.4 Additional Notes If we transfer personal data to countries outside the European Economic Area (EEA), we make sure that the recipient has an adequate level of data protection as defined in Article 45 of the GDPR or has implemented suitable safeguards as defined in Article 46 of the GDPR (such as Standard Contractual Clauses).
We use external service providers (subcontractors/processors) in some cases to provide our services, e.g. for IT services, hosting, payment processing, newsletter dispatch, applicant management, data destruction, facility services, or video conferencing software.
These service providers are contractually obliged under Art. 28 GDPR to process your data only in accordance with our instructions and in compliance with data protection regulations. Data will only be passed on to subcontractors if this is necessary for the purposes mentioned above.
6. PURPOSES OF PROCESSING
We use the information we collect for the following purposes:
- Service Provision: To provide the Dancefolio platform, manage user accounts, process memberships, and facilitate the “Claim Listing” functionality.
- Platform Visibility: To display user profiles and listings to the public in accordance with our “Visibility Logic” (see Section 7).
- Communication: To send administrative emails, newsletters, and notifications via third-party plugins and applications.
- Payment Processing: To process transactions for premium services or memberships via WooCommerce, WooPayments, and Stripe.
- Gamification: To track user points and rewards via myCred.
- Security: To protect the site from spam and abuse using Google reCAPTCHA and other security softwares.
- Analytics: To monitor traffic and user behavior using specific Analytics plugins.
- Social Integration: To allow social login and sharing via social media sharing applications.
You can request more information about the plugins, softwares and applications we use at any time by sending us an email at the email address provided in this agreement (Data Controller section). Such plugins, softwares and applications are able to manage your data to guarantee the normal functioning of the Platform and Your use of it.
7. ADVERTISEMENTS
We may display online advertisements and we may share aggregated and non-identifying information about our customers that we or our advertisers collect through your use of the Services. We do not share personally identifiable information about individual customers with advertisers. In some instances, we may use this aggregated and non-identifying information to deliver tailored advertisements to the intended audience.
We may also permit certain third-party companies to help us tailor advertising that we think may be of interest to Users and to collect and use other data about User activities on the Services. These companies may deliver ads that might place cookies and otherwise track User behavior.
Ad Networks Used: Google AdSense
Opt-Out: Users may learn more on how to opt out of interest-based advertising in the “California Privacy Rights” section below.
8. SOCIAL MEDIA FEATURES
Our Services may include social media features, such as social media share buttons, “Share This” buttons, etc (collectively, “Social Media Features”). These Social Media Features may collect your IP address, what page you are visiting on our Services, and may set a cookie to enable Social Media Features to function properly. Social Media Features are hosted either by their respective providers or directly on our Services. Your interactions with these Social Media Features are governed by the privacy policy of their respective providers.
9. EMAIL MARKETING
We offer electronic newsletters to which you may voluntarily subscribe at any time. We are committed to keeping your e-mail address confidential and will not disclose your email address to any third parties except as allowed in the information use and processing section or for the purposes of utilizing a third-party provider to send such emails.
In compliance with the CAN-SPAM Act, all e-mails sent from us will clearly state who the e-mail is from and provide clear information on how to contact the sender. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us. However, you will continue to receive essential transactional emails (e.g., password resets, order confirmations).
10. PUSH NOTIFICATIONS
We offer push notifications to which you may also voluntarily subscribe at any time. To make sure push notifications reach the correct devices, we use a third-party push notifications provider who relies on a device token unique to your device which is issued by the operating system of your device. While it is possible to access a list of device tokens, they will not reveal your identity, your unique device ID, or your contact information to us or our third-party push notifications provider. If, at any time, you wish to stop receiving push notifications, simply adjust your device settings accordingly.
Plugin Used: HP Search Alerts (Email/Push).
11. THE “VISIBILITY LOGIC” (PUBLIC VS. PRIVATE DATA)
You acknowledge and agree to the specific data visibility settings of the Dancefolio platform:
11.1 Public Profiles and Listings
- Scope: User profiles (Dancers, Teachers, Companies) and Job/Audition Listings created are ALWAYS PUBLIC, which means they will be visible and accessible to ALL Internet Users, inside and outside of the Platform. You have full control over what you publish and you can remove it at any time. The information you share on your public profile and in your listings must be considered public and it will be automatically considered already available elsewhere on the Internet (your website, social media pages, accounts, etc) whenever you publish it on Dancefolio.
- Accessibility: This information is indexed by search engines and is visible to both registered users and non-registered visitors.
- Intent: The purpose is to grant maximum visibility to the User for professional networking. You voluntarily consent to this public disclosure by creating a profile.
11.2 Resumes (CVs)
- Access Method: Resumes uploaded to the platform are accessible via Direct Link.
- Privacy Status: While not listed in a public directory, anyone who possesses the specific URL to your resume page can view, access and download it.
- User Responsibility: If you share this link, or if a third party shares this link, the content becomes accessible. We are not responsible for unauthorized access resulting from the sharing of these links. You acknowledge that you will share your resume and the information contained in it responsibly and that you will be fully responsible for the information displayed and any use made by other Users of the Internet. You also acknowledge that you will share such information at your own risk.
11.3 Private Messages
- Scope: Messages exchanged between users are PRIVATE.
- Access: These are accessible only to the sender, the recipient, and the Data Controller (for moderation and safety purposes).
12. THIRD-PARTY SERVICE PROVIDERS AND PLUGINS
We utilize a variety of WordPress plugins and third-party services to operate Dancefolio. These providers may process your Data on our behalf. Below is a categorized list of these processors and their functions:
12.1 Analytics and SEO
- Analytics Plugins (Google Analytics): Collects usage data, IP addresses, and behavioral metrics to analyze site performance.
- SEO plugins: Optimizes content for search engines. May process metadata and content structure.
- Google Fonts & Font Awesome: Loads external fonts. Your IP address may be transferred to Google or Fonticons, Inc. to retrieve these assets.
12.2 E-Commerce and Payments
- WooCommerce & WooPayments: Manages the online store functionality and order processing.
- Checkout Plugins – Stripe for WooCommerce: Processes credit card payments. Stripe is a PCI-DSS compliant provider. We do not store your financial data; it is transmitted directly to Stripe.
- Membership plugins: Manages paid access and verification status.
12.3 User Interaction and Content
- Listing and account management plugins (Core, Favorites, Reviews, Requests, Search Alerts): The core engine for user profiles, listings, and interactions. Stores all user-generated content and preference data.
- Fluent Forms: Collects data submitted through contact forms, application forms, and surveys.
- Poll: Collects user votes and opinions.
- Gamification plugins: Track user activity for the points/rewards system.
12.4 Social Media and Login
- Social media sharing plugins: Enables sharing of content to social platforms. These plugins may set cookies to track sharing activity.
12.5 Security and Maintenance
- Security plugin: Scans for malware and audits security logs. Collects IP addresses of all visitors to identify malicious actors.
- Google reCAPTCHA: Analyzes user behavior (mouse clicks, mouse movements) to distinguish humans from bots.
12.6 Infrastructure and Hosting
- GoDaddy: All data is physically stored on GoDaddy’s servers.
12.7 Compliance
- CookieYes | GDPR Cookie Consent: Manages user consent for cookies. Stores a cookie to remember your preferences so you are not asked repeatedly.
12.8. AI Assistants and Generative Tools Our Services include features powered by Artificial Intelligence (AI), such as our custom AI assistants (including but not limited to “Myrtha” and “Coppelius”) and AI-driven content generation tools (such as syllabus and curriculum architects). These tools are designed to assist dancers, teachers, and companies in generating educational content, receiving professional advice, and navigating the platform efficiently.
Data Processed by AI When you interact with our AI tools, we collect and process the text inputs, prompts, contextual parameters (e.g., duration types, goals), and any other information you type into the chat interfaces or submission forms exclusively to allow our AI tools to elaborate your prompts and give you the feedback the tool provides.
- User Warning: While our AI tools are designed to be helpful, you must not input highly sensitive personal data (such as financial information, government IDs, passwords, or specific medical conditions) into the AI chat interfaces.
Third-Party AI Sub-Processors To power these advanced features, Dancefolio utilizes third-party AI service providers and software, specifically OpenAI, L.L.C. (via their API) and the AI Power WordPress plugin suite.
- When you submit a prompt to Myrtha, Coppelius, or our generative tools, the text data is transmitted securely to OpenAI’s servers for processing to generate a response.
- OpenAI acts strictly as a Data Processor for this specific function.
Data Retention, Caching, and AI Model Training We respect your intellectual property and privacy regarding AI processing. Our architecture is designed with the following privacy-first principles:
- No Public Training on Your Data: In accordance with OpenAI’s API enterprise privacy policies, the data (prompts and generated responses) submitted via our platform’s API connection is NOT used by OpenAI to train, improve, or fine-tune their foundational public AI models. Your interactions remain private to our application.
- Third-Party Retention: OpenAI retains API data for a strict maximum of 30 days solely for the purpose of abuse and misuse monitoring, after which it is permanently deleted from their systems.
- Local Processing & Security: On the Dancefolio platform, AI interactions and generated content (such as syllabuses) may be temporarily cached and securely hashed on our local servers. This is done strictly to ensure platform scalability, optimize load times, prevent prompt-injection abuse, and manage rate-limiting to protect the platform from spam.
Automated Decision-Making Exemption Our AI tools are strictly for informational, educational, and generative assistance. They do not engage in profiling or automated decision-making that produces legal or similarly significant effects concerning you. The AI does not evaluate user resumes to make automated hiring, casting, or audition decisions; all such decisions remain entirely human-driven by the respective companies or schools.
13. COOKIE POLICY AND TRACKING TECHNOLOGIES
13.1 Use of Cookies Our Services use “cookies” to help personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. We use cookies to collect, store, and track information for security, personalization, and statistical purposes.
13.2 Types of Cookies Used
- Essential Cookies: Necessary for the functioning of the Website (e.g., WooCommerce cart cookies, session cookies).
- Analytics Cookies: Set by MonsterInsights and Google Analytics to track visitor usage.
- Advertising Cookies: Set by Google AdSense (“DoubleClick” cookie) to display personalized ads based on your browsing history.
- Social Media Cookies: Set by Sassy Social Share when you interact with share buttons.
13.3 Managing Cookies You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. You can also use the CookieYes banner on our site to manage your preferences.
14. RETENTION OF INFORMATION
14.1 Retention Period We will retain and use your Personal Information for the period necessary to comply with our legal obligations, as long as your user account remains active, and to enforce our agreements.
- Active Accounts: Data is retained indefinitely while the account is active to provide the Service.
- Inactive Accounts: We may retain user information for a period of up to 7 years after the user ceases to be an active user, for tax and legal liability purposes.
- Deletion: Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, and the right to rectification cannot be enforced after the expiration of the retention period.
15. SECURITY MEASURES
15.1 Safeguards We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access.
15.2 Data Breach In the event we become aware that the security of the Services has been compromised or Users’ Personal Information has been disclosed to unrelated third parties as a result of external activity (e.g., security attacks), we reserve the right to take reasonably appropriate measures, including investigation and reporting, and notification to law enforcement authorities. We will notify affected individuals via email if there is a reasonable risk of harm.
16. TRANSFER OF DATA (INTERNATIONAL TRANSFERS)
16.1 Transfers Outside the EU The Services are maintained in Italy, but we use service providers (like Google, Stripe, Automattic, GoDaddy) that may be located in the United States or other countries.
- Consent: By using the Website, you freely and specifically give us your consent to export your personal information to the United States and to store and use it in the United States.
- Safeguards: Transfers to countries outside the European Union will be made only if you have explicitly consented to it or in the cases provided for by the GDPR (e.g., Standard Contractual Clauses).
16. RIGHTS OF THE USER (GDPR COMPLIANCE)
If you are a resident of the European Economic Area (EEA) or the UK, you have the following rights under the GDPR:
- Right of Access (Art. 15): Obtain confirmation as to whether or not Personal Data concerning you is being processed and access that data.
- Right to Rectification (Art. 16): Obtain the rectification of inaccurate Personal Data.
- Right to Erasure (“Right to be Forgotten”) (Art. 17): Request the deletion of your Personal Data from our systems, subject to legal retention obligations.
- Right to Restriction of Processing (Art. 18): Request that we limit the processing of your data.
- Right to Data Portability (Art. 20): Receive your Personal Data in a structured, commonly used, and machine-readable format.
- Right to Object (Art. 21): Object to the processing of your Personal Data, particularly for direct marketing purposes.
- Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent.
- in accordance with Art. 7 (3) GDPR, to withdraw your consent at any time;
- in accordance with Art. 77 GDPR, to lodge a complaint with a supervisory authority
We do not use your personal data for automated individual decision-making within the meaning of Art. 22 GDPR.
How to Exercise Rights: Contact the Data Controller at info@dancefolio.org. We will respond within one month.
17. RIGHTS OF CALIFORNIA RESIDENTS (CCPA)
If you are a California resident, the CCPA grants you specific rights:
17.1 Notice of Collection and Sale
- Categories Collected: Identifiers (Name, Email), Internet Activity (Usage Data, Cookies), Professional Information (Resumes), Geolocation Data.
- Sale of Data: The use of Google AdSense on our website may constitute a “sale” of personal information under the CCPA.
- Right to Opt-Out: You have the right to opt-out of the sale of your Personal Information.
17.2 Additional Rights
- Right to Know: You may request disclosure of the specific pieces of Personal Information we have collected.
- Right to Delete: You may request the deletion of your Personal Information.
- Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.
18. CHILDREN’S PRIVACY (COPPA)
18.1 Age Restriction We do not knowingly collect Personal Information from children under the age of 13. If you are under the age of 13, please do not submit any Personal Information through the Services.
18.2 Minors (13-18) Minors over the age of 13 but under 18 may not use the Site by themselves. A parent or guardian can create an account on their behalf and such account must be FULLY managed by the parent or guardian. By registering, you warrant that you have such permission and that you will be fully and solely responsible of the information posted, published, uploaded or displayed on the minor’s account you are representing. Parents may contact us to review or delete their child’s information.
19. CHANGES TO THIS POLICY
We reserve the right to modify this Policy at any time. When we do, we will revise the “Last Updated” date at the top of this page. We may also provide notice to you via email or through a notification on the Website. Your continued use of the Services 48 hours after the effective date of the revised Policy constitutes your consent to those changes.
20. LEGAL ACTIONS AND LIABILITY
20.1 Defense of Rights The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
20.2 Limitation of Liability You acknowledge that the Owner is a Sole Proprietor. To the maximum extent permitted by applicable law, the Owner shall not be liable for any indirect, incidental, special, consequential, or punitive damages, or any loss of profits or revenues, whether incurred directly or indirectly, or any loss of data, use, goodwill, or other intangible losses, resulting from (a) your access to or use of or inability to access or use the Services; (b) any conduct or content of any third party on the Services; or (c) unauthorized access, use, or alteration of your transmissions or content.
21. CONTACT INFORMATION
If you have any questions, concerns, or complaints regarding this Policy, please contact us:
Dancefolio Management Email: info@dancefolio.org Web: Contact Form
[This document was last updated on February 4, 2023]