PRIVACY POLICY

Last updated January 22, 2025

This Privacy Policy for Emily Whitman (doing business as Engon Game Art) (“we,” “us,” or “our”), describes how and why we might access, collect, store, use, and/or share (“process”) your personal information when you use our services (“Services”), including when you:

Visit our website at https://www.engonart.com, or any website of ours that links to this Privacy Notice
Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at [email protected].

Summary of Key Points

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. When ordering or registering on our site, as appropriate, you may be asked to enter your name, email address, mailing address, credit card information, or other details to help with your experience.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.

How do we keep your information safe? Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit with us as safe as possible. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential. We implement a variety of security measure when a user places an order, enters, submits, or accesses their information to maintain the safety of your personal information. All transactions are processed through a gateway provider and are not stored or processed on our servers.

How do you exercise your privacy rights? The easiest way to exercise your rights is by visiting https://www.engonart.com/contact. We will consider and act upon any request in accordance with applicable data protection laws.

1. INFORMATION WE COLLECT

Personal information you disclose to us

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

Email addresses
Usernames
Passwords
Names
Contact preferences
Contact or authentication data
Billing addresses
Debit/credit card numbers
Purchase history
Course progress

Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is handled and stored by Kajabi. You may find their privacy notice link here: https://legal.kajabi.com/policies/privacy.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Policy: https://engonart.com/cookie-policy.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings.)

2. HOW WE PROCESS YOUR INFORMATION

We may process your personal information for a variety of reasons, depending on how you interact with our Services, including:

To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.

3. LEGAL BASES WE RELY ON TO PROCESS YOUR INFORMATION

We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with law, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
For investigations and fraud detection and prevention
For business transactions provided certain conditions are met
If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
For identifying inured, ill, or deceased persons and communicating with next of kin
If we have reasonable grounds to believe and individual has been, is, or may be a victim or financial abuse
If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or contravention of the laws of Canada or a province
If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
If the collection is solely for journalistic, artistic, or literary purposes
If the information is publicly available and is specified by the regulations

4. THIRD PARTY DISCLOSURE

We do not sell, trade, or otherwise transfer to outside parties your Personally Identifiable Information unless we provide users with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to keep this information confidential. We may also release information when appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety.

However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

The Services may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us, and which may link to other websites, services or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link towards a third-party website, service, or application does not imply endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third-party websites. Any data collected by third parties is not covered by this Privacy Policy. You should review the policies of such third parties and contact them directly to respond to your questions.

5. COOKIES AND OTHER TRACKING TECHNOLOGIES

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

To the extent these online tracking technologies are deemed to be a “sale”/”sharing” (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section “UNITED STATES RESIDENTS SPECIFIC PRIVACY RIGHTS.”

Specific information about how we use such technologies and how you can refuse certain cookies is set our in our Cookie Policy: https://www.engonart.com/cookie-policy.

6. HOW LONG WE KEEP YOUR INFORMATION

We will only keep your information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible, (for example, because your personal information has been stored in backup archives), then we will securely store your information and isolate it from any further processing until deletion is possible.

7. HOW WE KEEP YOUR INFORMATION SAFE

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process.

Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit with us as safe as possible. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential. We implement a variety of security measures when a user places an order, enters, submits, or accesses their information to maintain the safety of your personal information. All transactions are processed through a gateway provider and are not stored or processed on our servers.

8. COPPA (Children Online Privacy Protection Act)

When it comes to the collection of personal information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforce the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.

We do not specifically market to children under the age of 13 years old.

If you are under 13 years old, please do not provide any personal information on our website without the consent of a parent or guardian. We will obtain verifiable parental consent before collecting, using, or disclosing any personal information from children under 13 years old. Parents can contact us at [email protected] to access, review, or delete their child’s information.

9. YOUR PRIVACY RIGHTS

In some regions (like Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure, (iii) to restrict the processing of your personal information, (iv) if applicable, to data portability, and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section “HOW TO CONTACT US” below.

We will consider and act upon any request in accordance with applicable data protection laws.

Withdrawing your consent. If we rely on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You have the right to withdraw your consent at any time by contacting us using the contact details provided in the section “HOW TO CONTACT US” below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other that consent.

Opting out of marketing and promotional communications. You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section “HOW TO CONTACT US” below. You will then be removed from the marketing lists. However, we may still communicate with you – for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information

If you would like to review or change the information in your account at any time, you can:

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies. Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features of our Services. You may also opt out of interest-based advertising by advertisers on our Services. For further information, please see our Cookie Policy: https://engonart.com/cookie-policy.

If you have questions about your privacy rights, you may email us at [email protected].

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

California law requires us to let you know how we respond to web browser DNT signals. Because there is currently not an industry or legal stand for recognizing or honoring DNT signals, we do not respond to them at this time.

11. UNITED STATES RESIDENTS SPECIFIC PRIVACY RIGHTS

If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect

We have collected the following categories of personal information in the past twelve (12) months.

Category	Examples	Collected
A. Identifiers	Contact details, such as real name, alias, online identifier, Internet Protocol address, email address, and account name	YES
B. Personal information as defined in the California Customer Records statute	Name, contact information, financial information	YES
C. Protected classification characteristics under state or federal law	Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data	NO
D. Commercial information	Transaction information, purchase history, financial details, and payment information	NO
E. Biometric information	Fingerprints and voiceprints	NO
F. Internet or other similar network activity	Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements	YES
G. Geolocation data	Device location	NO
H. Audio, electronic, sensory, or similar information	Images and audio, video or call recording created in connection with our business activities	NO
I. Professional or employment-related information	Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us	NO
J. Education information	Student records and directory information	NO
K. Inferences drawn from collected personal information	Inferences drawn from any of the collected personal information listed above to create a profile or summary about an individual’s preferences	NO
L. Sensitive personal information	Debit or credit card numbers and account login information	YES

We only collect sensitive personal information, as defined by applicable privacy laws or the purposes allowed by law or with your consent. Sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You may have the right to limit the use or disclosure of your sensitive personal information.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

Receiving help through our customer support channels;
Participation in customer surveys or contests; and
Facilitation in the delivery of our Services and the respond to your inquiries.

We will use and retain the collected personal information as needed to provide the Services or for:

Category A – As long as the user has an account with us
Category B – As long as the user has an account with us
Category F – As long as the user has an account with us
Category L – As long as the user has an account with us

Sources of Personal Information

Learn more about the sources of personal information we collect in “INFORMATION WE COLLECT.”

How We Use and Share Personal Information

Learn more about how we use your personal information in the section “HOW WE PROCESS YOUR INFORMATION.”

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information in the section “THIRD PARTY DISCLOSURE.”

We may use your information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

Your Rights

You have rights under certain US stat data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

Right to know whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request the deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to non-discrimination for exercising your rights
Right to opt out of the processing or your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)

Depending on the state where you live, you may also have the following rights:

Right to access the categories of personal data being processed (Minnesota)
Right to obtain a list of the categories of third parties to which we have disclosed personal data (California, Delaware)
Right to obtain a list of specific third parties to which we have disclosed personal data (Minnesota, Oregon)
Right to review, understand, question, and correct how personal data has been profiled (Minnesota)
Right to limit use and disclosure of sensitive personal data (California)
Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (Florida)

How to Exercise Your Rights

To exercise these rights, you can contact us by visiting https://engonart.com/contact, by emailing us at [email protected], or by referring to the contact details at the bottom of this document.

We will honor your opt-out preferences if you enact the Global Privacy Control (GPC) opt-out signal on your browser.

Under certain US stat data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US State data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at [email protected]. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

12. UPDATES TO THIS POLICY

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “Revised” date at the top of the Privacy Policy. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

13. HOW TO CONTACT US ABOUT THIS POLICY

If you have questions or comments about this notice, you may email us at [email protected].

14. HOW TO REVIEW, UPDATE, OR DELETE DATA WE COLLECT

Based on the applicable laws of your country or state of residence in the U.S., you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to request we limit the use or disclosure of your personal information or withdraw your consent to our processing of you personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please visit: https://www.engonart.com/contact.