Our Privacy Policy outlines how we collect, use, and safeguard your data, ensuring transparency and trust.
ONCOURSE TECHNOLOGIES, INC.
PRIVACY POLICY
Effective: October 28, 2024
This Privacy Policy describes how OnCourse collects, uses, and discloses information associated with an identified or identifiable individual (referred to in this Privacy Policy as “Personal Data”)and what choices you have around this activity. If you have any questions, please don’t hesitate to contact us.When we refer to “OnCourse”, we mean OnCourseTechnology Limited, as explained in more detail in the “Identifying the DataController and Processor” section below.
Table of Contents:
1. Applicability of this Privacy Policy
2. Information We Collect and Receive
3. How We Process Your Information and Our Legal Bases for Doing So
4. How We Access, User, Store and Share Your Information
5. Data Retention
6. Security
7. Age Limitations
8. Changes to this Privacy Policy
9. International Data Transfers
10. Data Protection Officer
11. Identifying the Data Controller and Processor
12. Your Rights
13. California Privacy Rights
14. Data Protection Authority
15. Contacting OnCourse
This Privacy Policy applies to OnCourse’s software and other productivity tools and platforms (collectively, the “Software”), OnCourse.ai and other websites (collectively, the “Websites”) and other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with OnCourse.
If you do not agree with this Privacy Policy, then do not access or use the Software, Websites or any other aspect of OnCourse’s business. For the avoidance of doubt, this is the only privacy policy that applies to OnCourse.
This Privacy Policy does not apply to any third-party applications or software that integrate with the Software through the OnCourse platform (“Third-Party Software”), or any other third-party products, services or businesses that will provide their services under their own terms of service and privacy policy. In addition, a separate agreement, which may include our separate Terms of Service, governs delivery, access and use of the Software (the “Customer Agreement”), including the processing of data such as CRM data, messages, files or other content submitted through Software accounts (collectively, “Customer Data”).
The organization (e.g., your employer or another entity or person) that entered into the Customer Agreement (“Customer”) controls its instance of the Software and any associated Customer Data.
If you have any questions about specific settings and privacy practices, please contact us at privacy@oncouurse.ai.
California Notice of Collection of Personal Information: We collect the information described below under “Information We Collect and Receive” for the business and commercial purposes described below under “How we Access, Use, Share and Store Your Information .” To learn more about exercising your California PrivacyRights please review the “California Privacy Rights” section below.
OnCourse will collect and receive information through operation of the Software and Websites, and through other interactions with OnCourse.
Such information will include Customer Data and other information and data (“Other Information”) in a variety of ways:
Customers or individuals granted access to our Software by a Customer (“Authorized Users”) routinely submit Customer Data (such as messages, files or other content submitted through Software accounts) to OnCourse when using the Software.
OnCourse also collects, generates and/or receives the following categories of Other Information:
2.2.1 Account information: To create or update an account using our Software, you or our Customer (e.g. your employer) supply OnCourse with an email address, phone number, and/or other account set up. In addition, Customers that purchase a paid version of the Software provide OnCourse (or its payment processors) with billing details such as credit card information, banking information, and/or a billing address.
2.2.2 Usage information:
2.2.2.1 Software metadata. When an Authorized User interacts with the Software, metadata is generated that provides additional context about the way that an Authorized User uses the Software. For example, OnCourse logs the sessions, people, features, content, and links you view or interact with, the types of files shared and what Third-Party Software are used (if any).
2.2.2.2 Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Software and record it in log files. This log data may include your Internet Protocol (IP) address, the address of the web page you visited before using the Website or Software, browser type and settings, the date and time the Software were used, information about browser configuration and plugins, and your language preferences.
2.2.2.3 Device information. OnCourse may collect information about devices accessing the Software, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this Other Information often depends on the type of device used and its settings.
2.2.2.4 Location information. We may receive information from you, our Customers and other third-parties that helps us approximate your location. We may, for example, use a business address submitted by your employer (who is our Customer) or an IP address received from your browser or device to determine approximate location to assist with localization or for security purposes.
2.2.3 Cookie information: OnCourse uses a variety of cookies and similar technologies in our Websites and Software to help us collect Other Information. For more details about how we use these technologies, and your opt-out controls and other options, please visit our Cookie Policy.
2.2.4 Third-Party Software information: A Customer can choose to permit or restrict Third-Party Software for its accounts and OnCourse can receive personal data from such Third-Party Software. Typically, Third-Party Software is software that integrates with our Software, and a Customer can permit its Authorized Users to enable and disable these integrations for its accounts. OnCourse may also develop and offer OnCourse applications that connect the Software with a Third-Party Service. Once enabled, the provider of a Third-Party Service may share certain information with OnCourse.
When a Third-Party Service is enabled, OnCourse is authorized to connect and access Other Information made available to OnCourse in accordance with our agreement with the provider of the Third-Party Service and any permission(s) granted by our Customer (including, by its Authorized User(s)). Examples of information which OnCourse may receive in this manner include whether you successfully created a new account or interacted with a third-party application in a way that is attributable to OnCourse usage activity. We do not, however, receive or store passwords for any of these Third-Party Software when connecting them to the Software.
2.2.5 Contact information: In accordance with the consent process provided by your device or other third-party API, any contact information that an Authorized User chooses to import (such as importing student information from a device or API), forward or upload to the Software (for example, when sending emails to the Software) is collected when using the Software.
2.2.6 Third-Party data: OnCourse may receive data about organizations, industries, lists of companies that are customers, Website visitors, marketing campaigns and other matters related to our business from parent corporation(s), affiliates and subsidiaries, our partners, or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate-level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.
2.2.7 Audio and video metadata: OnCourse may receive, capture, and store metadata derived from your use of features such as video room conversations, and additional related data such as data regarding the date and time of your video room conversations and the Authorized User that you connected with.
2.2.8. CRM Data: In order to maximize the effectiveness of the Software and deliver the Services, OnCourse must integrate with a Customer's customer relationship management platform ("CRM"). OnCourse integrates with a Customer's CRM in order to (i) deliver inbound leads and related conversational data from its Software into the CRM for further handling by a Customer's team accessing such CRM, (ii) analyze and score inbound leads (iii) compare a Customer's historical lead and customer metadata with active inbound lead conversational data generated by our Software and (iv) to contact dormant or inactive leads ("Dormant Leads") contained in a Customer's CRM on a Customer's behalf through one or more channels including email, SMS and/or voice to attempt to revive or engage such Dormant Leads for the benefit of our Customer.
2.2.9 Additional information provided to OnCourse: We also receive Other Information when submitted to our Websites or in other ways, such as responses or opinions you provide if you participate in a focus group, contest, activity or event, feedback you provide about our products or services, information you provide if you apply for a job with OnCourse, enroll in a certification program or other educational program hosted by OnCourse or a vendor, request support, interact with our social media accounts or otherwise communicate with OnCourse.
Generally, no one is under a statutory or contractual obligation to provide any Customer Data or Other Information (collectively, “Information”). However, certain Information is collected automatically and, if some Information, such as account setup details, is not provided, we may be unable to provide the Software.
Customer Data will be used by OnCourse in accordance with a Customer’s instructions, including to provide the Software, any applicable terms in the Customer Agreement, a Customer’s use of Software functionality, and as required by applicable law.
OnCourse is a processor of Customer Data and the Customer is the controller. Customer may, for example, use the Software to grant and remove access to a account, assign roles and configure settings, access, modify, export, share, and remove Customer Data, and otherwise apply its policies to the Software.OnCourse uses Other Information to operate our Software,Websites, and business. More specifically, OnCourse uses Other Information for the following purposes:
OnCourse processes Other Information when we comply with a legal obligation including, for example, to access, preserve or disclose certain information if there is a valid legal request from a regulator, law enforcement or others. For example, a search warrant or production order from law enforcement to provide information in relation to an investigation, such as your IP address. We use account information, Usage information, Cookie information, Third-Party Software Information, Contact information, Third-Party data, Audio and video metadata, CRM Data and Additional information provided to OnCourse for compliance with a legal obligation.
3.2 Legitimate Interests: We rely on our legitimate interests or the legitimate interests of a third-party where they are not outweighed by your interests or fundamental rights and freedoms ("legitimate interests"). We use account information, Usage information, Cookie information, Third-Party Software Information, Contact information, Third-Party data, Audio and video metadata, CRM Data and Additional information provided to OnCourse for the following legitimate interests:
3.2.1 To provide, update, maintain and protect our Software, Websites and business. This includes the use of Other Information to support delivery of the Software under a Customer Agreement, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities, or at an Authorized User’s request. It is in our and your interests to provide, update, maintain and protect our Software, Websites, and business.
3.2.2 To develop and provide search, learning and productivity tools and additional features. OnCourse tries to make the Software as useful as possible for Customers and their end users. For example, we may improve the Software by using CRM Data and Other Information to analyze and score leads, help determine and rank the relevance of content, channels or expertise to an Authorized User; make Software or Third-Party Service suggestions based on historical use and predictive models; identify organizational trends and insights; customize a Software experience; or create new productivity features and products.
3.2.3 To investigate and help prevent security issues and abuse. We may use a variety of tools such as device fingerprinting to prevent issues and abuse. We may process, including in an automated fashion, Other Information to better understand how OnCourse is used or to prevent spam or abuse. It is in our interest to keep the Service secure and to detect, prevent, and address abuse (such as spam) and to investigate and take action in respect of suspicious activity on the Software.
3.2.4 To aggregate or de-identify information. In some cases, we aggregate or de-identify information we have associated with you and use the resulting information, for example, to improve the Software. It is in our interest to research and improve the Software; It is in the interests of Customers to practice data minimisation and privacy by design in respect of their information.
3.2.5 Share information with others including law enforcement and to respond to legal requests. It is in our interest and the interest of the general public to prevent and address fraud, unauthorized use of OnCourse, violations of our terms or other harmful or illegal activity; to protect ourselves, our users or others, including as part of investigations or regulatory enquiries; or to prevent death or imminent bodily harm.
3.2.6 Transfer, store or process your information outside the European Economic Area. As the Websites and Software operate globally, with Customers around the world, we need to share information we collect globally. We carry out necessary transfers outside the European Economic Area, including to Australia, Canada, Japan, India, South Korea, and the United States, to provide, update, maintain and protect our Software, Websites and business.For more information, review the “International Data Transfers” section below. In our and your interests to provide, update, maintain and protect our Software, Websites and business.
3.2.7 To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Other Information to respond. It is in our, our Customers’ and Authorized Users’ interests to facilitate communication (for example to answer questions from Customers).
3.2.8 To send service emails and other communications. For example, we may: send you service, technical and other administrative emails, messages, and other types of communications; or contact you to inform you about changes in our Software, our Software offerings, and important Software-related notices, such as security and fraud notices. These communications are considered part of the Software and you may not opt out of them. It is in our Customers and Authorized Users’ interests to address service related issues. We use account information and Usage information for the following legitimate interests:
3.2.9 For billing, account management and other administrative matters. OnCourse may need to contact you for invoicing, account management, and similar reasons and we use account data to administer accounts and keep track of billing and payments. It is in our interest to facilitate the effective provision and administration of the Websites and Software.
3.2.10 To send marketing emails and other communications. We sometimes send emails about new product features, promotional communications or other news about OnCourse. These are marketing messages so you can control whether you receive them. If you have additional questions about a message you have received from OnCourse please get in touch through the contact mechanisms described below. It is in our interest to promote the Websites and Software and send our direct marketing.
This section describes how OnCourse may access, use, share and store Information, as described in the section entitled 'Information We Collect and Receive' above. Customers determine their own policies and practices for the sharing and disclosure of Information to third parties. OnCourse does not control how a Customer or any third party chooses to share or disclose Information. We may share and disclose your Information when providing the Software:
4.1 The Customer’s Instructions. OnCourse may share and disclose Information in accordance with a Customer’s instructions and with appropriate consent, including any applicable terms in the Customer Agreement and theCustomer’s use of Software functionality and in compliance with applicable law and legal process. Some sharing at a Customer’s request may incur additional fees.
4.1.1 To enable OnCourse to follow our Customers’ instructions, OnCourse provides administrator controls to allow Customers to manage their accounts. For example, we follow our Customers’ instructions to enable or disable Authorized Users use of various features of the Software, such as the administrative dashboard.
4.1.2 We also follow Customer and Authorized User instructions on how an Authorized User’s profile may be displayed within an account or when shared through other features.
4.1.3 Customers may also provide their Authorized Users with the ability to adjust the audience and visibility of certain Customer Data.4.2 Displaying the Software. When an Authorized User submits Information, it maybe displayed or discoverable to other Authorized Users in the same or connected account(s). For example, an Authorized User’s email address may be displayed with their profile, or other profile and organizational information may be displayed to Authorized Users.
4.3 Collaborating with Others.
The Software provides different ways for AuthorizedUsers working to collaborate and interact. Information, such as an AuthorizedUser’s profile and organizational information, may be shared, subject to the policies and practices of the account(s) you use. For example, depending on the settings of your account, to enable connections with other Authorized Users, your profile may be shared or searchable or discoverable by Authorized Users. OnCourse may include either administrator controls or user controls, depending on the use case, with respect to external collaboration.Authorized Users may also decide to expand the visibility of certain content and Customer Data, such as files.
4.4. Customer access.
Owners, administrators, Authorized Users, and other Customer representatives and personnel may be able to access, modify, or restrict access to Information. This may include, for example, your employer using features of the Software to access or modify your profile details, or to export logs of account activity.
4.5 Third-Party service providers and partners.
We may engage third-party companies or individuals as service providers or business partners to process Information and support our business. These third parties may, for example, provide virtual computing and storage services, assist OnCourse with verifying Owners and Customers, or we may share business information to develop strategic partnerships with Third-Party service providers to support our common customers. In this respect, depending on the Third-Party service provided, OnCourse may share your Information.
4.6 Third-Party Software.
A Customer may enable, or permit Authorized Users to enable, Third-Party Software. We require each Third-Party Service provider to disclose all permissions for information accessible through the Software, but we do not guarantee that they do so. When Third-Party Software are enabled by aCustomer or an Authorized User, OnCourse may share Information with Third-Party Software. Third-Party Software are not owned or controlled by OnCourse and third parties that have been granted access to Information may have their own policies and practices for its collection, use, and sharing. Please check the permissions, privacy settings, and notices for these Third-Party Software or contact the provider for any questions.
4.7 Forums.
The Information you choose to provide in any community forum that may exist in the future, including personal data, will be publicly available.
4.8 Organizers and sponsors of Events/Webinars.
If you attend an event or webinar organized by OnCourse, we may share your profile and organizational information with the event or webinar sponsors when you register, have your badge scanned, or join a breakout room. If required by applicable law, you may consent to such sharing via the registration form or by allowing your attendee badge to be scanned at a sponsor booth. In these circumstances, your information will be subject to the sponsors’ privacy statements. For more information, please refer to the terms provided when youregister for such an event or webinar
4.9 Professional advisers.
We may share your Information with professional advisers acting as service providers, processors, controllers, or joint controllers - including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services, and to the extent we are legally obliged to share or have a legitimate interest in sharing your Information containing personal data.
4.10 Corporate Affiliates.
OnCourse may share Information with our corporate affiliates, parents and/or subsidiaries.
4.11 During a Change to OnCourse’s Business.
If OnCourse engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of OnCourse’s assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all of the Information described in the ‘Information We Collect and Receive’ section may be shared or transferred, subject to standard confidentiality arrangements.
4.12 Aggregated or De-identified Data.
We may disclose or use aggregated or de-identified Information for any purpose. For example, we may share aggregated or de-identified Information with prospects or partners for business or research.
4.13 Law Enforcement and Regulators.
If we receive a request for information, we may disclose Other Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process.
4.14 To enforce our rights, prevent fraud, and for safety.
To protect and defend the rights, property, or safety of OnCourse, its users, or third parties, including enforcing its contracts or policies, or in connection with investigating and preventing illegal activity, fraud, or security issues, including to prevent death or imminent bodily harm.
4.15 With Consent.
OnCourse may share Information with third parties when we have consent to do so or as otherwise permitted in this Privacy Policy. For accounts registered to corporate entities, OnCourse may share Information with consent of the account primary owner or authorized corporate officer, or their designee. For accounts created without a formal corporate entity affiliation, OnCourse may require user consent.
OnCourse will retain Customer Data in accordance with a Customer’s instructions (including to perform any applicable terms in the Customer Agreement and through Customer’s use of Software functionality) and as required by applicable law. Customer may customize its retention settings and, depending on the Software plan, apply those customized settings. The Customer may also apply different settings to messages, files or other types of Customer Data.
The deletion of Customer Data and other use of the Software by the Customer may result in the deletion and/or de-identification of certain associated Other Information.
OnCourse may retain Other Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy (such as to provide the Software, including any optional features you use, and to provide customer support).
This may include keeping your Other Information after you have deactivated your account for the period of time needed for OnCourse to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce our agreements.
OnCourse takes security of data very seriously. OnCourse works hard to protect Information you provide from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Information we collect, process and store, and the current state of technology.
Given the nature of communications and information processing technology, OnCourse cannot guarantee that Information during transmission through the Internet or while stored on our systems or otherwise in our care will be absolutely safe from intrusion by others. When you click a link to a third-party site, you will be leaving our site and we don’t control or endorse what is on third-party sites.
OnCourse does not allow use of our Software and Websites by anyone younger than 13 years old, to the extent prohibited by applicable law. If you learn that anyone younger than 13 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.
OnCourse may change this Privacy Policy from time to time. Laws, regulations, and industry standards evolve, which may make those changes necessary, or we may make changes to our services or business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, OnCourse will provide additional notice, such as via email or through the Software. If you disagree with the changes to this Privacy Policy, you should deactivate your Software account. Contact the Customer if you wish to request the removal of Personal Data under their control.
OnCourse may transfer your Personal Data to countries other than the one in which you live, including transfers to the United States. To the extent that Personal Data is transferred abroad, OnCourse will ensure compliance with the requirements of the applicable laws in the respective jurisdiction in line with OnCourse’s obligations.In particular, we offer the following safeguards if OnCourse transfers Personal Data from jurisdictions with differing data protection laws:
9.1. European Commission’s Standard Contractual Clauses.
OnCourse uses Standard Contractual Clauses approved by the European Commission (and the equivalent standard contractual clauses for the UK where appropriate) for transfers to, among others, Australia, Canada, India, Japan, South Korea, and the United States. OnCourse will transfer your Personal Data to facilitate the provision of the Software.
9.2 Asia-Pacific Economic Cooperation Cross-Border Privacy Rules System And Privacy Recognition For Processors.
OnCourse’s privacy practices, described in this Privacy Policy, comply with the Asia-Pacific Economic Cooperation (“APEC”) Cross Border Privacy Rules (“CBPR”) system and the Privacy Recognition for Processors (“PRP”). The APEC CBPR system provides a framework for organizations to ensure protection of personal data transferred among participating APEC economies and the PRP demonstrates an organization’s ability to provide effective implementation of a personal data controller’s privacy obligations related to the processing of personal information. More information about the APEC framework can be found here. If you have an unresolved privacy or data use concern related to our APEC CBPR or PRP certifications that we have not addressed satisfactorily, you may contact us at legal@oncourse.ai.
Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, Customer is the controller of Customer Data. In general, OnCourse is the processor of Customer Data and the controller of Other Information.
Individuals in the European Economic Area, the United Kingdom, Brazil, and across the globe have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to your personal information, as well as to seek to update, delete, or correct this information.
You can do this using the settings and tools provided in your Software account. If you cannot use the settings and tools, contact the Customer who controls your account for additional access and assistance.To the extent that OnCourse’s processing of your Personal Data is subject to the General Data Protection Regulation or other applicable laws requiring a legal basis for processing Personal Data, such as the UK DataProtection Act and the Brazilian General Data Protection Act (Lei Geral de Proteção de Dados), OnCourse primarily relies on its legitimate interests, described above, to process your Personal Data. Where we rely on legitimate interests to process your Personal Data, you can object to that processing by contacting us as described in the “Contacting OnCourse” section below. In response to your objection, we will stop processing your information for the relevant purposes unless we have compelling grounds in the circumstances or the processing is necessary in the context of legal claims. OnCourse may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to OnCourse’s use of yourPersonal Data for this purpose at any time.
This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA,” as amended by theCalifornia Privacy Rights Act or “CPRA”. California law requires that we detail the categories of personal information that we collect and disclose for certain “business purposes,” such as to service providers that assist us with securing our services or marketing our products, and to such other entities as described in earlier sections of Privacy Policy. In addition to the information provided above in the ‘Information We Collect And Receive’ section, we collect the following categories of personal information from you, your employer, data analytics providers, data brokers, and Third-Party Software for our business purposes:- Identifiers/contact information;- Commercial information;- Internet or electronic network activity information;- Financial information;- Geolocation information;- Professional or employment-related information;- Audio and visual data;- In limited circumstances where allowed by law, information that may be protected under California or United States law;- and Inferences drawn from any of the above categories.OnCourse does not sell (as such term is defined in the CCPA or otherwise) the personal information we collect (and will not sell it without providing a right to opt out). We may also share personal information (in the form of identifiers and internet activity information) with third party advertisers for purposes of targeting advertisements on non-OnCourse websites, applications, and services. In addition, we may allow third parties to collect personal information from our sites or services if those third parties are authorized service providers who have agreed to our contractual limitations as to their retention, use, and disclosure of such personal information, or if you use our sites or services to interact with third parties or direct us to disclose your personal information to third parties.Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use, disclose, or may sell this information), to delete their personal information, to opt out of any “sales”, to know and opt out of sharing of personal information for delivering advertisements on non-OnCourse websites, and to not be discriminated against for exercising these rights.California consumers may make a request pursuant to their rights under the CCPA by contacting us at privacy@oncourse.ai.
We will verify your request using the information associated with your account, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf. Authorized agents must submit proof of authorization.If you would like to opt-out of sharing activity based on your cookie identifiers, turn on a Global Privacy Control in your web browser or browser extension.
Please see the California Privacy Protection Agency’s website at https://oag.ca.gov/privacy/ccpa for more information on valid Global Privacy Controls. If you would like to opt-out of sharing activity based on other identifiers (like email address or phone number), contact us in accordance with the “Contacting OnCourse” section, below.For more information on OnCourse’s role and obligations under the CCPA, please visit their website.
Subject to applicable law, you also have the right to (i) restrict OnCourse’s use of Other Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority. If, however, you believe that we have not been able to assist with your complaint or concern, and you are located in the European Economic Area or the UnitedKingdom, you have the right to lodge a complaint with the competent supervisory authority. If you work or reside in a country that is a member of the EuropeanUnion or that is in the EEA, you may find the contact details for your appropriate data protection authority on the following website. If you are a resident of the United Kingdom you may contact the UK supervisory authority, the Information Commissioner’s Office.
Please also feel free to contact OnCourse if you have any questions about this Privacy Policy or OnCourse’s practices, or if you are seeking to exercise any of your statutory rights. OnCourse will respond within a reasonable timeframe. You may contact us at privacy@oncourse.ai.
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