Terms of Service for Dysphagia Cafe
1. Introduction
These Terms of Service (“Terms”) govern your access to and use of the Dysphagiacafe.com educational platform, including any associated websites, applications, content, courses, and other services provided by Dysphagia Cafe (collectively, the “Service”). These Terms constitute a legally binding agreement between you and Dysphagia Cafe (“we,” “us,” or “our”). By accessing or using our Service, you acknowledge that you have read, understood, and agree to be bound by these Terms.
2. Definitions
“User,” “you,” and “your” refer to the individual or entity accessing or using the Service.
“Content” refers to any courses, lessons, texts, images, videos, audio, or other material that appears on or through the Service.
“User Content” refers to any Content that users submit, upload, or transmit to or through the Service.
“Educational Materials” refers to courses, lessons, assignments, quizzes, and other educational resources available through the Service.
“Intellectual Property Rights” means all patent rights, copyright rights, moral rights, rights of publicity, trademark rights, trade dress and service mark rights, goodwill, trade secret rights, and other intellectual property rights.
3. Acceptance of Terms
By accessing or using our Service, you agree to be bound by these Terms and our Privacy Policy, which is incorporated by reference. If you are using our Service on behalf of an organization, you represent and warrant that you have the authority to bind that organization to these Terms. If you do not agree to these Terms, you may not access or use our Service.
4. Changes to Terms
We reserve the right to modify these Terms at any time. We will provide notice of significant changes by posting a prominent notice on our Service or by sending you an email. Your continued use of our Service after any such changes constitutes your acceptance of the revised Terms. If you do not agree to the revised Terms, you must stop using our Service.
5. Eligibility
To use our Service, you must be at least 13 years old. If you are under 18 years old, you may only use the Service with the consent and supervision of a parent or legal guardian who agrees to be bound by these Terms. Certain courses or features may have additional age restrictions, which will be specified in the course description.
6. Educational Content and No Guarantee
While we strive to provide accurate and up-to-date educational content, we do not guarantee the accuracy, completeness, or reliability of any Content or Educational Materials available through our Service. The Educational Materials are provided for general informational and educational purposes only and do not constitute professional advice. Educational content is intended for professional clinicians. If material is consumed not by a clinician, material should not replace the advise of a specialist in dysphagia. Seek the advice of your medical doctor when appropriate.
Completion of courses or programs does not guarantee any particular outcome, including employment, admission to educational institutions, certification, or specific knowledge acquisition. Your results may vary based on your effort, background knowledge, and other factors.
7. User Accounts
You may be required to create an account to access certain features of our Service. You are responsible for:
– Providing accurate, current, and complete information
– Maintaining the confidentiality of your password and account
– All activities that occur under your account
– Notifying us immediately of any unauthorized use of your account
We reserve the right to suspend or terminate your account at our discretion if we believe you have violated these Terms or if we believe your account may pose a risk to our Service or other users.
8. Subscription and Payment Terms
Access to certain Educational Materials may require payment of fees. Unless otherwise specified at the time of purchase:
– All prices are stated in USD
– Course purchases are one-time fees that provide access for the period specified at the time of purchase
Prices for our Service are subject to change with notice. We will notify you of any price changes before they take effect. Your continued use of the Service after a price change takes effect constitutes your agreement to pay the changed amount.
9. Refund Policy
For individual course purchases, we offer a 15-day satisfaction guarantee. If you are not satisfied with a course, you may request a refund within 15 days of purchase by contacting us at Jonathan@dysphagiacafe.com.
For any special courses, like the NYC Dysphagia Symposium, all payment terms and refund policies with be specific on the registration page.
10. User Content
You may have the opportunity to submit User Content to the Service, including comments, questions, assignments, or forum posts. You retain ownership of any User Content you submit, but you grant us a worldwide, non-exclusive, royalty-free license (with the right to sublicense) to use, copy, reproduce, process, adapt, modify, publish, transmit, display, and distribute such User Content in any media or distribution methods. This license authorizes us to make your User Content available to other users of the Service and to use your User Content for educational purposes.
You represent and warrant that you have all necessary rights to grant us this license and that your User Content does not violate any third-party rights or applicable laws.
We reserve the right to remove any User Content at our discretion.
11. Academic Integrity
You agree to maintain the highest standards of academic integrity when using our Service. Prohibited conduct includes, but is not limited to:
– Cheating or attempting to cheat on assignments, quizzes, or exams
– Plagiarizing or submitting work that is not your own without proper attribution
– Sharing your account credentials with others
– Distributing Educational Materials to non-enrolled users
– Attempting to obtain unauthorized assistance on assignments or assessments
– Falsifying information or misrepresenting your identity
Violation of these academic integrity standards may result in termination of your account and access to the Service without refund.
12. Prohibited Conduct
You agree not to:
– Violate any applicable law or regulation
– Infringe the rights of others, including intellectual property rights
– Harass, abuse, or harm another person
– Interfere with the proper functioning of our Service
– Attempt to breach any security or authentication measures
– Use our Service for any illegal or unauthorized purpose
– Access or attempt to access other users’ accounts without authorization
– Post or transmit malicious code or other harmful computer code
– Scrape, crawl, or otherwise extract data from our Service without permission
– Impersonate others or misrepresent your affiliation with any person or entity
– Copy, reproduce, or distribute Educational Materials without authorization
13. Intellectual Property
All Content provided by Dysphagia Cafe, including but not limited to Educational Materials, text, graphics, logos, icons, images, audio clips, digital downloads, data compilations, and software, is the property of Dysphagia Cafe or its content suppliers and is protected by international copyright, trademark, and other intellectual property laws. The compilation of all Content on the Service is the exclusive property of Dysphagia Cafe and is protected by international copyright laws.
Our trademarks and trade dress may not be used in connection with any product or service without the prior written consent of Dysphagia Cafe.
We grant you a limited, non-exclusive, non-transferable, revocable license to access and use the Educational Materials for your personal, non-commercial educational purposes only. This license does not include the right to:
– Copy, reproduce, or distribute the Educational Materials
– Modify, adapt, or create derivative works based on the Educational Materials
– Use the Educational Materials for commercial purposes
– Remove or alter any copyright or trademark notices contained in the Educational Materials
14. DMCA Copyright Policy
We respect the intellectual property rights of others and expect our users to do the same. We will respond to notices of alleged copyright infringement that comply with applicable law. If you believe any materials accessible on or from our Service infringe your copyright, you may request removal of those materials by submitting written notification via email to Jonathan@dysphagiacafe.com
15. Privacy Policy
Your privacy is important to us. Our Privacy Policy, which is incorporated into these Terms by reference, explains how we collect, use, and disclose information about you. By using our Service, you consent to the collection, use, and disclosure of your information as described in our Privacy Policy.
16. Third-Party Links and Services
Our Service may contain links to third-party websites, affiliates or services that are not owned or controlled by Dysphagia Cafe. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party websites or services. You further acknowledge and agree that Dysphagia Cafe shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with the use of or reliance on any such content, goods, or services available on or through any such websites or services.
17. Disclaimer of Warranties
OUR SERVICE AND EDUCATIONAL MATERIALS ARE PROVIDED “AS IS” AND “AS AVAILABLE” WITHOUT WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, AND NON-INFRINGEMENT. Dysphagia Cafe DOES NOT WARRANT THAT OUR SERVICE IS ACCURATE, COMPLETE, RELIABLE, CURRENT, OR ERROR-FREE, OR THAT THE EDUCATIONAL MATERIALS WILL MEET YOUR REQUIREMENTS OR EXPECTATIONS. Dysphagia Cafe DISCLAIMS ALL LIABILITY FOR ANY ERRORS, OMISSIONS, OR INACCURACIES IN THE CONTENT PROVIDED THROUGH OUR SERVICE.
18. Limitation of Liability
TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL BE LIABLE FOR ANY SPECIAL, INCIDENTAL, INDIRECT, OR CONSEQUENTIAL DAMAGES WHATSOEVER. SOME STATES DO NOT ALLOW THE EXCLUSION OR LIMITATION OF INCIDENTAL OR CONSEQUENTIAL DAMAGES, SO THE ABOVE LIMITATION MAY NOT APPLY TO YOU.
19. Indemnification
You agree to indemnify, defend, and hold harmless Dysphagia Cafe, its officers, directors, employees, agents, and affiliates from and against any and all claims, liabilities, damages, losses, costs, expenses, or fees (including reasonable attorneys’ fees) that such parties may incur as a result of or arising from your violation of these Terms, your User Content, or your use of the Service. Dysphagia Cafe reserves the right to assume the exclusive defense and control of any matter otherwise subject to indemnification by you, in which event you will cooperate with Dysphagia Cafe in asserting any available defenses.
20. Governing Law
These Terms shall be governed by and construed in accordance with the laws of the State of Georgia, without regard to its conflict of law provisions. Our failure to enforce any right or provision of these Terms will not be considered a waiver of those rights.
21. Dispute Resolution
Any disputes arising from these Terms will be resolved through binding arbitration in accordance with the American Arbitration Association rules. The arbitration shall take place in [Marietta, Georgia]. You agree to waive any right to a jury trial.
22. Entire Agreement
These Terms, including our Privacy Policy, constitute the entire agreement between you and Dysphagia Cafe regarding your use of our Service and supersede any prior agreements between you and Dysphagia Cafe relating to your use of our Service.
23. Waiver and Severability
The failure of Dysphagia Cafe to enforce any right or provision of these Terms will not be deemed a waiver of such right or provision. If any provision of these Terms is found to be invalid or unenforceable, the remaining provisions will remain in full force and effect.
24. Assignment
These Terms, and any rights and licenses granted hereunder, may not be transferred or assigned by you without the prior written consent of Dysphagia Cafe, but may be assigned by Dysphagia Cafe without restriction.
25. Termination
We reserve the right to suspend or terminate your access to our Service at our sole discretion, with or without notice, for conduct that we believe violates these Terms or is harmful to other users of our Service, us, or third parties, or for any other reason. Upon termination, your right to use our Service will cease immediately.
26. Contact Information
If you have any questions about these Terms, please contact us at Jonathan@dysphagiacafe.com.
Last Updated: 2025-06-16
## Regulatory Compliance
### General Data Protection Regulation (GDPR) Compliance
The following provisions apply to users protected by European Union regulations:
## Data Collection Under GDPR
In compliance with the General Data Protection Regulation (GDPR), we collect and process your personal data only when we have a lawful basis to do so. This includes processing based on your consent, to fulfill a contract with you, to comply with a legal obligation, to protect your vital interests, to perform a task in the public interest, or for our legitimate interests where those don’t override your fundamental rights and freedoms.
We collect only the minimum data necessary for the purposes specified in this policy. When we request your consent to process your data, you have the right to withdraw that consent at any time.
## Data Processing Under GDPR
We process personal data in accordance with the principles outlined in the GDPR:
– **Lawfulness, fairness, and transparency**: We process data lawfully, fairly, and in a transparent manner.
– **Purpose limitation**: We collect data for specified, explicit, and legitimate purposes and do not process it in a manner incompatible with those purposes.
– **Data minimization**: We limit data collection to what is necessary for the purposes for which it is processed.
– **Accuracy**: We take reasonable steps to ensure personal data is accurate and kept up to date.
– **Storage limitation**: We keep data in a form that permits identification only as long as necessary for the purposes of processing.
– **Integrity and confidentiality**: We process data in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage.
We maintain records of our data processing activities and conduct data protection impact assessments where required by law.
## Your Rights Under GDPR
If you are located in the European Economic Area (EEA), you have the following rights with respect to your personal data:
– **Right to access**: You can request a copy of the personal data we hold about you.
– **Right to rectification**: You can request that we correct inaccurate or incomplete data about you.
– **Right to erasure**: You can request that we delete your personal data in certain circumstances.
– **Right to restrict processing**: You can request that we restrict the processing of your data in certain circumstances.
– **Right to data portability**: You can request to receive your data in a structured, commonly used, and machine-readable format.
– **Right to object**: You can object to our processing of your personal data in certain circumstances.
– **Rights related to automated decision-making**: You can request human intervention in automated decisions that significantly affect you.
To exercise these rights, please contact us at Jonathan@dysphagiacafe.com. We will respond to your request within 30 days.
## International Data Transfers
If we transfer your personal data outside the European Economic Area (EEA), we will ensure that appropriate safeguards are in place to protect your data, such as:
– Transferring to countries deemed by the European Commission to provide adequate protection
– Using Standard Contractual Clauses approved by the European Commission
– Adopting Binding Corporate Rules for transfers within our corporate group
– Where applicable, relying on derogations for specific situations such as your explicit consent or the necessity to perform a contract with you
You have the right to obtain information about the safeguards we use to transfer your personal data outside the EEA by contacting us at Jonathan@dysphagiacafe.com.
### California Consumer Privacy Act (CCPA) Compliance
The following provisions apply to users protected by California, United States regulations:
## Information Collection Notice for California Residents
Under the California Consumer Privacy Act (CCPA), we are required to inform California residents about the categories of personal information we collect and the purposes for which we use this information.
In the past 12 months, we have collected the following categories of personal information:
– Identifiers (such as name, email address, IP address)
– Commercial information (such as products purchased or considered)
– Internet or other electronic network activity (such as browsing history)
– Geolocation data
– Inferences drawn from other personal information
We use this information for the business and commercial purposes described in our Privacy Policy.
## California Privacy Rights
If you are a California resident, you have the following rights under the CCPA:
– **Right to know**: You can request information about the personal information we have collected about you and how we have used and disclosed it.
– **Right to delete**: You can request the deletion of your personal information, subject to certain exceptions.
– **Right to opt-out**: You can opt out of the sale of your personal information, if applicable.
– **Right to non-discrimination**: We will not discriminate against you for exercising any of your CCPA rights.
To exercise your rights, you can submit a verifiable consumer request by contacting us at Jonathan@dysphagiacafe.com or through the methods described in our Privacy Policy. You may make a request up to twice within a 12-month period. We will respond to your request within 45 days, with a possible extension of up to 45 additional days when reasonably necessary.
## California Do Not Sell My Personal Information
Under the CCPA, California residents have the right to opt-out of the sale of their personal information. [DOES/DOES NOT] sell personal information as defined by the CCPA.
IF APPLICABLE: To opt out of the sale of your personal information, please contact us at Jonathan@dysphagiacafe.com.
## Lei Geral de Proteção de Dados (LGPD) Compliance
The following provisions apply to users protected by Brazil regulations:
## Legal Basis for Processing Under LGPD
In accordance with the Brazilian General Data Protection Law (LGPD), we only process your personal data when we have a legal basis to do so. These legal bases include:
– With your consent
– To fulfill a contract with you or to take steps at your request before entering into a contract
– To comply with a legal or regulatory obligation
– For the regular exercise of rights in judicial, administrative, or arbitration proceedings
– For our legitimate interests, provided these interests do not override your fundamental rights and freedoms
– To protect credit (in accordance with applicable legislation)
– For the protection of your life or physical safety, or the life or physical safety of a third party
– For health procedures, when processing is performed by health professionals or health entities
– To perform public policy studies and research
– For the regular exercise of rights in contracts or judicial, administrative, or arbitration proceedings
## Your Rights Under LGPD
If you are located in Brazil, the LGPD provides you with specific rights regarding your personal data. You have the right to:
– Confirmation of the existence of processing of your personal data
– Access to your personal data
– Correction of incomplete, inaccurate, or outdated data
– Anonymization, blocking, or deletion of unnecessary or excessive data
– Portability of your data to another service provider
– Deletion of personal data processed with your consent
– Information about public and private entities with which we have shared your data
– Information about the possibility of not providing consent and the consequences
– Revocation of consent
To exercise any of these rights, please contact us at Jonathan@dysphagiacafe.com at the contact information provided below. We will respond to your request within 15 days.
## Personal Information Protection and Electronic Documents Act (PIPEDA) Compliance
The following provisions apply to users protected by Canada regulations:
## Consent Under PIPEDA
In accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA), we obtain your consent when we collect, use, or disclose your personal information. The form of consent may vary depending on the circumstances and the type of information collected. Express consent is generally obtained when the information is likely to be considered sensitive, while implied consent may be appropriate when the information is less sensitive.
You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. However, please note that withdrawing your consent may affect our ability to provide you with certain products or services.
## Canadian Privacy Rights
Under PIPEDA, you have the right to:
– Access your personal information held by us
– Challenge the accuracy and completeness of your personal information
– Have your personal information amended where inaccurate or incomplete
– Withdraw your consent to the continued use and disclosure of your personal information
To exercise these rights, please contact our Privacy Officer at Jonathan@dysphagiacafe.com. We will respond to your request within 30 days, unless an extension is warranted.
## Cross-Border Data Transfers
Your personal information may be stored and processed in Canada or other countries where we or our service providers maintain facilities. By using our services, you consent to the transfer of information to countries outside your country of residence, which may have different data protection rules than in your country.
When we transfer your personal information to other countries, we will protect that information as described in this Privacy Policy and in accordance with applicable law. We take steps to ensure that third parties involved in processing your data maintain appropriate data protection safeguards.
### Protection of Personal Information Act (POPIA) Compliance
The following provisions apply to users protected by South Africa regulations:
## Processing Principles Under POPIA
In compliance with the Protection of Personal Information Act (POPIA), we process your personal information in accordance with the following principles:
– **Accountability**: We are responsible for ensuring compliance with POPIA principles
– **Processing limitation**: We process your information lawfully and minimally
– **Purpose specification**: We collect information for specific, explicitly defined purposes
– **Further processing limitation**: We only use your information for purposes compatible with those for which it was collected
– **Information quality**: We take reasonable steps to ensure your information is complete, accurate, and not misleading
– **Openness**: We maintain documentation about our processing activities and notify you when collecting your information
– **Security safeguards**: We secure the integrity and confidentiality of your information
– **Data subject participation**: We facilitate your right to access and correct your information
We only process your personal information if we have a lawful basis, including your consent, contractual necessity, legal obligation, or our legitimate interests.
## Your Rights Under POPIA
As a data subject under POPIA, you have the right to:
– Request confirmation of whether we hold your personal information
– Request access to your personal information
– Request correction or deletion of inaccurate, irrelevant, excessive, outdated, incomplete, misleading, or unlawfully obtained personal information
– Object to the processing of your personal information in certain circumstances
– Object to the processing of your personal information for direct marketing purposes
– Not be subject to a decision based solely on automated processing
– Submit a complaint to the Information Regulator
– Institute civil proceedings regarding alleged interference with your personal information
To exercise these rights, please contact Jonathan@dysphagiacafe.com.
### Australian Privacy Principles (APPs) Compliance
The following provisions apply to users protected by Australia regulations:
## Australian Privacy Principles Compliance
We comply with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth). The APPs govern how we collect, use, disclose, store, and provide access to your personal information. We are committed to:
– Being open and transparent about how we manage your personal information
– Only collecting personal information that is reasonably necessary for our functions or activities
– Notifying you about the collection of your personal information
– Only using or disclosing your personal information for the purpose for which it was collected, or for a related purpose you would reasonably expect
– Taking reasonable steps to protect your personal information from misuse, interference, loss, and unauthorized access, modification, or disclosure
– Providing you with access to your personal information upon request
– Correcting inaccurate, out-of-date, incomplete, irrelevant, or misleading personal information
For more detailed information about how we handle your personal information, please refer to our Privacy Policy.
## Your Privacy Rights in Australia
Under the Privacy Act and the APPs, you have the right to:
– Request access to the personal information we hold about you
– Request correction of any personal information that is inaccurate, out-of-date, incomplete, irrelevant, or misleading
– Make a complaint about a breach of the APPs
– Opt out of receiving direct marketing communications from us
– Request information about our privacy practices and handling of your personal information
To exercise these rights, please contact our Privacy Officer at Jonathan@dysphagiacafe.com. We will respond to your request within a reasonable timeframe (usually within 30 days).
## Disclosure to Overseas Recipients
We may disclose your personal information to overseas recipients, such as service providers or affiliated entities located outside Australia. When we do so, we take reasonable steps to ensure that the overseas recipient does not breach the APPs in relation to your personal information.
The countries where overseas recipients may be located include United States. By providing your personal information, you consent to this disclosure.
If a third-party overseas recipient handles your personal information in a way that breaches the APPs, we may be accountable under the Privacy Act, and you may not be able to seek redress under the Privacy Act against the overseas recipient.
### Canada’s Anti-Spam Legislation (CASL) Compliance
The following provisions apply to users protected by Canada regulations:
## Consent for Electronic Communications
In compliance with Canada’s Anti-Spam Legislation (CASL), we obtain appropriate consent before sending commercial electronic messages (CEMs) to electronic addresses. We may rely on either express or implied consent:
– **Express consent** means you have actively agreed to receive our communications, which remains valid until you withdraw it.
– **Implied consent** may arise from an existing business relationship, existing non-business relationship, conspicuous publication of your address, or voluntary disclosure of your address to us without indicating you do not wish to receive CEMs.
When requesting your express consent, we clearly identify the purpose for which consent is sought, provide our contact information, and inform you that you can withdraw your consent at any time.
## Unsubscribe Mechanism
Every commercial electronic message we send includes a clear and prominent unsubscribe mechanism that allows you to withdraw your consent to receive future messages. The unsubscribe mechanism:
– Is easy to use and at no cost to you
– Can be executed through the same electronic means by which the message was sent, or if that is not practicable, through another electronic means
– Specifies an electronic address or link to a webpage to which the unsubscribe request may be sent
When you unsubscribe, we will honor your request within 10 business days. We will not charge a fee, require you to provide personal information beyond your electronic address, or make you take any steps other than sending a reply email or visiting a single webpage to unsubscribe.
## CASL Compliance Statement
We are committed to compliance with Canada’s Anti-Spam Legislation (CASL). This means we:
– Obtain appropriate consent before sending commercial electronic messages
– Clearly identify ourselves in all communications
– Provide our contact information in all communications
– Honor all unsubscribe requests promptly
– Do not alter transmission data without consent
– Do not install computer programs without consent
If you have questions about our CASL compliance practices or believe you have received a message from us that does not comply with CASL, please contact us at [CONTACT_INFORMATION].
## Additional Terms
## Virtual Events and Webinars
### Registration and Access
Access to our virtual events, webinars, and online conferences (collectively, “Virtual Events”) requires registration and, in some cases, payment of applicable fees. Upon successful registration, we will provide you with access credentials or instructions. These credentials are personal to you and may not be shared, transferred, or distributed to any third party.
### Recordings and Content Use
Virtual Events may be recorded, and by participating, you grant us permission to record, store, and distribute your likeness, voice, and any content you share during the event. You retain ownership of any original content you provide, but grant us a non-exclusive, worldwide, royalty-free license to use, reproduce, distribute, and display such content in connection with our services.
Recordings of Virtual Events are protected by copyright and may be made available to registrants for a limited time after the live event. You may not record, reproduce, share, distribute, modify, or create derivative works from our Virtual Events without our express written permission.
### Participant Conduct
When participating in Virtual Events, you agree to:
– Conduct yourself in a professional and respectful manner
– Not engage in disruptive behavior that interferes with others’ experience
– Not share inappropriate, offensive, or illegal content
– Not engage in marketing, solicitation, or commercial activities unless explicitly permitted
– Comply with any additional guidelines provided for specific events
We reserve the right to remove participants who violate these conduct guidelines without refund or to deny access to future events.
### Technical Requirements and Limitations
Access to Virtual Events requires compatible hardware, software, and internet connection. We are not responsible for technical issues on your end that prevent or impair your participation. While we make reasonable efforts to ensure platform stability, we do not guarantee uninterrupted access to Virtual Events and are not liable for technical failures outside our control.
### Cancellation and Rescheduling
We reserve the right to reschedule, modify, or cancel Virtual Events. In case of cancellation, paid registrants will receive a refund or credit for a future event, at our discretion. If you are unable to attend a Virtual Event for which you have registered, please contact Jonathan@dysphagiacafe.com
### Disclaimers
Virtual Event content is provided for informational purposes only and does not constitute professional advice. We do not guarantee any particular outcome or result from applying information obtained during Virtual Events. Opinions expressed by presenters or participants other than our official representatives do not necessarily reflect our views and policies.
## Data Processing Terms
### Scope and Roles
These Data Processing Terms apply when we process personal data on your behalf in the course of providing our Services. For the purpose of these terms, you are the “Data Controller” and we are the “Data Processor” as those terms are defined in applicable data protection laws.
These terms supplement our Terms of Service and form a Data Processing Agreement (“DPA”) between you and us. In case of any conflict between these Data Processing Terms and the rest of our Terms of Service, these Data Processing Terms shall prevail with respect to the processing of personal data.
### Processing Obligations
We will:
– Process personal data only on your documented instructions, including with regard to transfers of personal data to a third country or international organization
– Ensure that persons authorized to process the personal data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality
– Implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk of processing
– Assist you, taking into account the nature of processing, in responding to requests from data subjects
– Assist you in ensuring compliance with security, breach notification, impact assessment, and consultation obligations under applicable data protection laws
– At your choice, delete or return all personal data to you after the end of the provision of services relating to processing
– Make available to you all information necessary to demonstrate compliance with these obligations and contribute to audits, including inspections, conducted by you or an auditor mandated by you
### Data Transfers
We will only transfer personal data to countries outside the European Economic Area (EEA) or other protected jurisdictions where appropriate safeguards are in place. These safeguards may include:
– Adequacy decisions by relevant authorities
– Standard contractual clauses approved by relevant authorities
– Binding corporate rules
– Other valid transfer mechanisms
### Data Breach Notification
We will notify you without undue delay after becoming aware of a personal data breach affecting the personal data we process on your behalf. Our notification will include, to the extent possible:
– The nature of the breach
– The categories and approximate number of data subjects concerned
– The categories and approximate number of personal data records concerned
– The likely consequences of the breach
– The measures taken or proposed to address the breach and mitigate possible adverse effects
### Records of Processing
We will maintain records of our processing activities as required by applicable data protection laws. Upon your reasonable request, we will make these records available to you to demonstrate our compliance with these Data Processing Terms.
## Accessibility
### Commitment to Accessibility
We are committed to making our Services accessible to all users, including those with disabilities. We strive to conform to WCAG 2.1 Level AA standards (Web Content Accessibility Guidelines) and applicable laws regarding accessibility.
### Accessibility Features
Our Services may include the following accessibility features:
– Text alternatives for non-text content
– Captions and other alternatives for multimedia
– Content that can be presented in different ways without losing information
– Functionality that is available from a keyboard
– Sufficient time for users to read and use content
– Content that does not cause seizures or physical reactions
– Ways to help users navigate and find content
– Text that is readable and understandable
– Content that appears and operates in predictable ways
– Input assistance to help users avoid and correct mistakes
– Compatibility with current and future user tools
### Third-Party Content
While we strive to ensure all content on our Services is accessible, we may not have control over all third-party content or applications that may be integrated into our Services. We cannot guarantee that such third-party content will meet all accessibility requirements.
### Feedback and Assistance
If you experience any difficulty accessing any part of our Services, or if you require assistance or have suggestions for improving accessibility, please contact us at [ACCESSIBILITY_CONTACT]. We welcome your feedback and are committed to continually improving the accessibility of our Services.
### Accessibility Statement
