OUR APPROACH TO PRIVACY
1. Commitment to Privacy
Aroma Ecaterina Education, Inc. (the “Company,” “we,” “our,” or “us”) is dedicated to safeguarding your privacy. This Privacy Policy outlines how we collect, store, process, transfer, share, disclose, and use data and personal information that identifies or is associated with you (“personal information”), as well as our use of cookies and similar technologies.
2. Who We Collect Information From
We collect personal information about individuals who are our direct customers. Where our customer is a business or similar entity, we also collect personal information about individuals who are employees, agents, or representatives of that customer. These individuals are referred to as “you” and “your” throughout this Privacy Policy.
3. Services Covered by This Policy
The Company provides information and links for customers to browse, subscribe, and access sales copy pages, checkout pages, enrollment pages, advertisements, and other marketing materials (collectively, the “Services”). These are available at aroma-ecaterina.com or any other websites operated by Aroma Ecaterina Education, Inc., its subsidiaries, or affiliates (together referred to as our “Websites”).
4. Scope of this Privacy Policy
This Privacy Policy applies to our Websites and the Services. By accessing our Websites or using our Services, you confirm that you have read and understood this Privacy Policy.
5. Consent to Use of Personal Information
By submitting personal information to the Company, you consent to its collection, use, storage, processing, and disclosure as outlined in this Privacy Policy. If you do not agree to these terms, please refrain from providing personal information to the Company.
6. Third-Party Websites and Services
This Privacy Policy does not apply to websites, services, applications, payment gateways, or payment processing platforms that may be accessed through our Websites. The Company accepts no responsibility or liability for the privacy practices of third-party websites. Before submitting personal information to any third-party website, please review their privacy policies.
PERSONAL INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE IT
7. Information You Provide Directly
We collect personal information when you voluntarily submit it to us through our Websites or Services. This includes information you provide when registering for an account, filling out forms, corresponding with us via our Websites, social media, phone, or email, subscribing to mailing lists or newsletters, responding to surveys, or engaging with features of the Services as they become available.
8. Types of Personal Information Collected
Personal information may include, but is not limited to:
• Name, date of birth, financial information, home address, and phone number.
• IP address, location data, weblogs, browser details, referring web addresses, searches conducted, and pages visited.
• Occupation, title, and other details you choose to provide.
9. Requirement for Certain Services
Certain Services can only be provided if you supply the necessary personal information. If you choose not to provide the required information, the Company may be unable to offer those Services to you.
10. Categories and Purposes of Data Collection
Annex 1 (attached) details:
• Categories of personal information collected.
• Purposes for collection and usage.
• Legal bases for processing personal information.
• Categories of recipients to whom personal information may be disclosed.
• Retention periods for each category of personal information.
11. Information Collected Automatically
We also collect personal information indirectly, including details about how you access and use the Services and the devices you use to do so. This data may include device information, usage patterns, and other technical details. We may link or combine this indirectly collected information with personally identifiable information you provide directly, enabling us to deliver a personalized and seamless experience.
12. Data Minimization
The Company endeavours to collect only the personal information necessary for the purposes outlined in Annex 1. Personal information will not be used or disclosed for purposes other than those for which it was collected, except with your consent or as required or permitted by law.
13. Anonymized and Aggregated Data
We may anonymize and aggregate the personal information we collect, including data related to your subscribers, website visitors, or customers. Anonymized information, which does not directly identify individuals, may be used for purposes such as:
• Testing IT systems.
• Conducting research and data analysis.
• Improving our Services.
• Developing new products and features.
We may also share anonymized and aggregated data with third parties for these purposes.
CUSTOMER DATA WE MAY COLLECT THROUGH THE PROVISION OF OUR SERVICES
14. Collection of Customer Data
During the provision of Services, we may collect personal information about individuals who are subscribers, website visitors, or customers of our customers (referred to as “Customer Data”).
15. Rights and Licenses
By submitting or causing Customer Data to be submitted to us, you represent and warrant that you have obtained all necessary rights and permissions to grant the Company and its subcontractors or service providers the rights required to provide the Services.
If the Company shares or publicly discloses information derived from Customer Data (including for marketing purposes or application development), such data will be anonymized or aggregated to a commercially reasonable extent to prevent the identification of specific individuals. You further agree that the Company retains an indefinite right to use, store, transmit, distribute, modify, copy, display, sublicense, and create derivative works of such anonymized and aggregated data.
16. Your Representations and Warranties
In connection with Customer Data, you represent, warrant, and agree to the following:
a. You have lawfully obtained or will lawfully obtain Customer Data and have not used any fraudulent, deceptive, or improper means to collect or cause the collection of Customer Data by the Company.
b. The Customer Data does not and will not violate any applicable laws or infringe upon any person’s or entity’s intellectual property or proprietary rights.
c. Customer Data has been collected in compliance with a privacy policy that permits the Company to collect, use, and disclose such data under this Privacy Policy, and, where applicable, you have obtained any necessary consents required by law.
d. You are solely responsible for ensuring compliance with all applicable privacy laws and regulations in all relevant jurisdictions related to Customer Data.
e. The Company may exercise its rights in Customer Data as granted here without liability or cost to any third party.
f. Customer Data complies with this Privacy Policy.
For clarity, the Company assumes no responsibility or liability for Customer Data. You are solely responsible for the Customer Data you provide and for any consequences arising from its collection or sharing. You must not submit or cause to be submitted any Customer Data containing sensitive information, including but not limited to social security numbers, passport numbers, driver’s license numbers, credit or debit card details, employment information, financial data, health information, or any other data subject to specific privacy or security laws.
17. Data Breach and Security Responsibilities
• If Customer Data is disclosed to or accessed by an unauthorized party, the Company will promptly notify you and use reasonable efforts to cooperate with your investigation of the incident.
• If the Company has a valid, good-faith belief that unauthorized access to Customer Data has occurred, we will notify you promptly and provide reasonable cooperation for your investigation.
Third-Party Notice Requirements: If an incident involving Customer Data triggers third-party notice requirements, you (not the Company) will bear sole responsibility for:
• The timing, content, cost, and method of such notice.
• Compliance with all applicable laws related to such notifications.
Data Security and Backup Responsibility:
You are solely responsible for ensuring the adequate security, protection, and backup of Customer Data when it is in your possession or the possession of your representatives or agents. The Company is not responsible for actions taken by your authorized users involving Customer Data, and you are fully responsible for any consequences arising from their actions.
STORING AND TRANSFERRING YOUR PERSONAL INFORMATION
18. Security Measures
We implement commercially reasonable physical, technical, and organizational safeguards to preserve and protect the integrity and security of your personal information from accidental or unlawful destruction, loss, alteration, or damage. All personal information collected is stored on secure servers, and electronic transactions conducted through our Websites are protected by SSL encryption technology.
When registering for an account on the Services, you are responsible for maintaining the security of your account, including using strong passwords, as outlined in our Terms of Service. While we take measures to protect your information, we cannot guarantee that unauthorized third parties will never bypass our security systems or misuse your personal information. You acknowledge that you provide your personal information at your own risk.
19. Disclosure of Information in Business Transactions
We do not sell or rent your personal information to non-affiliated third parties, except as permitted by law or as outlined in this Privacy Policy. However, in the event of a sale of all or substantially all of our business, or a similar transaction, your personal information may be transferred to a purchaser or prospective purchaser. The purchaser may collect, use, and disclose your personal information to evaluate the proposed transaction, operate the acquired business, or for purposes outlined in this Privacy Policy.
20. Cross-Border Data Transfers
The personal information we collect may be transferred to, stored, and processed in countries outside your jurisdiction, depending on the locations of our operations and those of our third-party service providers. For users in the European Union (“EU”), personal information may be processed in countries outside the EU, including the United States. These transfers are necessary to fulfill our agreement to provide the Services.
General Data Privacy Regulation (GDPR)
21. Compliance with GDPR
The GDPR, effective May 25, 2018, protects the data of EU citizens. Although we do not specifically target marketing to the EU or conduct significant business in or to the EU, we will comply with applicable portions of the GDPR if your data falls under its jurisdiction.
If you are a resident of the European Economic Area (EEA) or are accessing our site from the EEA, you may have rights under the GDPR, including the right to:
• Access, correct, delete, or restrict the processing of your data.
• Port your data to another service provider.
• Object to certain types of data processing, including direct marketing.
• Exercise the “right to be forgotten.”
To exercise any of these rights, please contact our GDPR representative at info@aroma-ecaterina.com.
22. Third-Party Service Providers
When engaging third-party service providers to store, process, or handle personal information on our behalf (e.g., data processing or office services), we use contractual and other measures to ensure an appropriate level of protection while your information is in their care.
23. Limitations of Security
While we strive to protect your personal information, security incidents may occur, resulting in the loss, disclosure, or alteration of data. Submitting information via the Internet inherently involves some risk, and we cannot guarantee the security of data in transit. Any submission of personal information is at your own risk.
YOUR RIGHTS IN RESPECT OF YOUR DATA
24. Your Rights
You have specific rights regarding your personal information under applicable privacy laws:
a. Right of Access and Portability: Obtain access to your personal information and receive it in a portable format.
b. Right to Rectification: Request the correction of inaccurate or incomplete personal information without undue delay.
c. Right to Erasure: Request the deletion of your personal information in certain circumstances, such as when it is no longer necessary for the purposes for which it was collected or processed.
d. Right to Restriction: Request the restriction of processing of your personal information in certain circumstances, such as when the accuracy of the data is contested.
e. Right to Object: Object to the processing of your personal information based on your specific situation, or object to processing for direct marketing purposes.
25. How to Exercise Your Rights
To exercise any of these rights, please contact us using the contact details provided at the end of this Privacy Policy.
26. Right to File a Complaint
You have the right to lodge a complaint with your local data protection authority. For information on contacting your local data protection authority, visit this link.
https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
COOKIES AND SIMILAR TECHNOLOGIES
27. Data Collection During Use
When you use our Services, read our emails, visit our Websites, or engage with us via a computer or mobile device, we and our third-party service providers automatically collect information about you and the device you use. This includes your preferences and activities on our Websites. We use this information to enhance and personalize your user experience, improve our Websites and Services, and for other internal purposes.
28. Tracking Technologies
We use various tracking technologies to collect this information, including cookies, Flash objects, web beacons, embedded scripts, location-identifying technologies, and similar tools (collectively, “tracking technologies”). This data may be combined with personal information you provide directly to us.
29. Cookies and Their Purpose
Our Websites use cookies to distinguish you from other users, enabling us to personalize your experience by storing your preferences (e.g., user ID, language choice, or region). A cookie is a small data file stored on your device’s hard drive (computer or smartphone) for record-keeping purposes.
30. Types of Cookies We Use:
a. Strictly Necessary Cookies: Essential for the operation of our Websites, such as authentication and fraud prevention.
b. Analytical/Performance Cookies: Help us count visitors, analyze website traffic, and improve functionality based on user behavior.
c. Functionality Cookies: Remember your preferences (e.g., region, language) to offer personalized content.
d. Targeting Cookies: Record your visits, pages viewed, and links clicked to tailor advertisements to your interests. We may share this data with third parties for these purposes.
31. Analytics Tools
We may use analytics tools, such as Google Analytics, to measure website traffic and user behavior. For more information about Google’s practices, visit Google’s Privacy Policy, and to opt out, visit Google Analytics Opt-Out.
32. Cross-Device Tracking
We work with third-party partners to implement technologies, including statistical modeling, that recognize and contact you across multiple devices.
33. Do Not Track Signals
At this time, we are unable to respond to Do Not Track (DNT) signals set by your browser.
34. Managing Cookies
Most browsers allow you to adjust your cookie settings. However, disabling cookies may limit your ability to use certain features of our Websites. Instructions for managing cookies can usually be found in your browser’s “options” or “preferences” menu. For more information about managing cookies, visit All About Cookies.
35. Non-Cookie Tracking Technologies
Deleting cookies does not remove non-cookie technologies like Local Storage Objects (e.g., Flash objects, HTML5). You can manage Flash cookies through Adobe’s settings. Some browsers may provide tools to manage HTML5 Local Storage Objects.
36. Email Tracking
When we send emails, we may track which emails are opened and which links are clicked using single-pixel gifs (web beacons). This information helps us analyze email campaign performance and improve our communication.
37. URL Click Tracking
We may also track when a URL in our emails is clicked to measure link engagement. This tracking does not collect personal information and is used for aggregate reporting.
MARKETING AND ADVERTISING
38. Marketing Communications
Occasionally, we may contact you with information about our Services. These communications will primarily be sent via email and are designed to provide relevant updates and offers.
39. Opting Out
If you no longer wish to receive marketing communications, you can opt out by clicking the unsubscribe link at the bottom of our emails. However, you cannot opt out of non-promotional messages, such as account updates, security notices, or changes to our Services.
THIRD-PARTY DATA COLLECTION AND INTEREST-BASED ADVERTISING
40. Interest-Based Advertising
We participate in interest-based advertising, enabling third-party advertisers, social media companies, and advertising networks to display targeted ads based on your browsing activity. This may involve collecting information through cookies or similar technologies about your visits to our Websites, apps, and other online services.
41. Purpose of Interest-Based Advertising
We and our third-party partners use this data to make ads more relevant to your interests and for purposes such as reporting, attribution, and market research.
42. Opting Out of Interest-Based Advertising
To opt out of interest-based advertising, you can use these resources:
• Network Advertising Initiative (NAI)
• Digital Advertising Alliance (DAA)
• Your Online Choices
You may also adjust settings on your mobile device:
• iOS: Enable “Limit Ad Tracking.”
• Android: Enable “Opt-Out of Interest-Based Ads.”
Additionally, you can use the AppChoices app for mobile ad management.
43. Device-Specific Opt-Outs
Opting out through the above tools will apply only to the specific browser or device. To stop receiving interest-based ads across all devices, you must opt out on each browser and device individually.
44. Cookies and Opt-Outs
Some opt-out options may not work if your browser blocks cookies. If you delete cookies, change browser settings, or switch devices, you may need to opt out again.
CONSENT
45. Consent to Collect, Use, and Disclose Personal Information
Wherever possible, we will obtain express consent to collect, use, and disclose personal information directly from the individual. However, depending on the sensitivity of the personal information, consent may be implied, deemed (using an opt-out mechanism), or expressed.
If you provide personal information about another individual, you represent and warrant that you have obtained the necessary consent or authority to allow the Company to collect, use, and disclose such personal information as described in this Privacy Policy, or that such collection, use, and disclosure are permitted by applicable law.
46. Withdrawing Consent
You may withdraw your consent to the use and disclosure of your personal information or opt out of specific uses and disclosures at any time. To do so, please contact us using the details provided at the end of this Privacy Policy.
LINKS TO THIRD PARTY SITES
47. Third-Party Websites
Our Websites may contain links to third-party websites. If you choose to follow a link, note that those websites have their own privacy policies, and we do not accept responsibility or liability for their practices. By using our links, you release us from any responsibility for third-party actions or omissions. Always review the privacy policies of such websites before providing personal information.
POLICY TOWARD CHILDREN
48. Age Restrictions
Our Websites are intended for use only by individuals who have reached the age of majority under applicable law and can legally enter into binding contracts. Access to our Websites and Services is prohibited in jurisdictions where it is illegal or restricted.
49. Children’s Data
We do not knowingly collect personal information from individuals under the age of majority. If you believe a child under the age of majority has provided us with personal information, please contact us at info@aroma-ecaterina.com. We encourage parents and guardians to monitor children’s online activities.
CHANGES TO THIS POLICY
50. Updates
We may update this Privacy Policy periodically. The “last modified” date will reflect any changes. Updates are effective upon posting to our Websites, so we encourage you to review this page regularly.
NOTICE TO YOU
51. Communication Methods
If we need to communicate with you for legal, marketing, or other business purposes, we will select the most appropriate method, such as email or notices on our Websites. While you may opt out of certain communications, non-promotional notifications (e.g., account updates) cannot be disabled.
CONTACTING US
52. Data Protection Inquiries
For questions or concerns about this Privacy Policy, please contact:
Aroma Ecaterina Education
Address: CH-6900 Lugano, Dufour 19
Email: info@aroma-ecaterina.com
This Privacy Policy was last modified 2025.
Annex 1 – Categories of Personal Information Collected
1. CONTACT INFORMATION AND BASIC PERSONAL DETAILS
1. Contact Information and Basic Details
• Examples: Full name, phone number, postal address, email address, and zip code.
• Purpose: Communication, authentication, account creation, and service delivery.
• Legal Basis: Contract performance, legitimate interests, and legal obligations.
2. Business and Marketing Information
• Examples: Company websites, IP addresses, software in use, marketing data, and business goals.
• Purpose: Service optimisation, advertising, and handling inquiries.
• Legal Basis: Contract performance and legitimate interests.
3. Payment Information
• Examples: Credit card details, billing and shipping addresses.
• Purpose: Payment processing and fraud prevention.
• Legal Basis: Contract performance and legitimate interests.
4. Correspondence and Comments
• Examples: Email or survey responses, message board posts.
• Purpose: Addressing questions, feedback, and marketing.
• Legal Basis: Legitimate interests.
5. All Personal Information
• Purpose: Fraud detection, communication, and service improvement.
• Legal Basis: Legitimate interests.
Categories of Recipients
1. Group of Companies
• Personal information may be shared within our corporate group for operational purposes.
2. Service Providers
• Includes vendors providing mailing, payment processing, analytics, or fraud prevention services.
3. Partners
• Partners may receive information to provide promotional content or related services, in compliance with this Policy.
4. Business Transactions
• Data may be disclosed during mergers, acquisitions, or sales.
5. Legal and Regulatory Compliance
• Personal information may be shared with authorities when required by law or for security purposes.
RETENTION PERIOD
We retain personal information only as long as necessary for its intended purpose and in compliance with legal obligations and legitimate business interests.
GENERAL DISCLAIMER
Aroma Ecaterina Business Group Inc. (“We” or “the Company”) makes no guarantees regarding the accuracy or reliability of the information on our Websites.
• No Warranties: We disclaim liability for errors, omissions, or outdated content.
• Limitation of Liability: Under no circumstances will we be liable for damages, including lost profits or business interruptions.
• Income Disclaimer: Statements about earnings are illustrative and not guaranteed. Results vary based on individual factors.
By using our Websites, you accept these terms and assume all associated risks. For questions, contact info@aroma-ecaterina.com.
Return Policy
Physical Merchandise
• All sales are final. Orders may only be canceled or modified within 24 hours of purchase.
Digital Products
• All sales of digital or downloadable products are final and non-refundable.
Event Tickets
• All ticket sales are final, except where covered by a Money Back Guarantee. Modifications or cancellations are allowed within 24 hours of purchase.
For modifications or refunds, email info@aroma-ecaterina.com with complete order details.
This policy was last amended in 2025.