Counter Culture US, Inc., a Delaware corporation doing business as Keens Academy (“Keens Academy,” “Keens,” “we,” “us,” or “our”), provides online K-pop training, classes, practice, coaching, and assessment services. This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information through our websites, applications, classes, assessments, and related services (collectively, the “Services”).
Operator and Contact Address: Counter Culture US, Inc., 2035 Sunset Lake Road, Suite B-2, Newark, Delaware, United States
Privacy Contact: [email protected]
Keens Academy serves learners in multiple countries, including children. If a learner is under 13 in the United States, or below the parental-consent age that applies where the learner lives, the separate Children’s Privacy Notice and Verifiable Parental Consent also applies.
1. Scope
This Policy applies to personal information processed by Keens Academy in connection with the Services. It does not apply to a third party’s independent services, websites, or privacy practices. A third party that processes information only for Keens Academy under contract is treated as a service provider as described below.
2. Information We Collect
A. Account and Contact Information
We may collect:
- full name, display name, username, and account identifier;
- email address, telephone number, country or region, language, and time zone;
- password hash, authentication information, account settings, and support history;
- enrollment, subscription, transaction, and billing status; and
- parent or legal guardian name, contact details, relationship, authority, and verification information when required.
Payment processors may collect payment-card details directly under their own privacy notices. Keens Academy may receive transaction status and limited billing information needed to administer the account.
B. Age and Eligibility Information
We may collect date of birth, age, age range, country or region, and information needed to determine whether adult or parental consent is required. We may request reasonable evidence to verify a parent or guardian’s identity and authority.
C. Profile and Learning Information
We may collect stage name, training interests, skill level, goals, preferences, class history, attendance, completion status, achievements, practice records, training plans, areas for improvement, and instructor communications.
D. Assessment, Video, Audio, and Feedback Information
If a user chooses a feature that requires a recording or upload, we may collect:
- video, audio, images, thumbnails, captions, transcripts, and related metadata;
- assessment responses and performance submissions;
- instructor, coach, or automated observations;
- scores, levels, feedback, progress history, and recommendations; and
- upload, review, processing, and deletion records.
The camera is intended to remain off by default unless a user selects a feature that reasonably requires it. Available camera-off learning and practice features may be used without submitting an assessment recording.
Practice mirror. The practice room in our apps can show the device's front camera on the screen as a live mirror next to the class video. That live view is displayed on the device only: it is not recorded, stored, transmitted, or analyzed, and no audio is captured. A user may practice with the camera off.
No facial recognition or biometric processing. Keens Academy does not use facial recognition, face tracking, face-geometry mapping, or any other technology that identifies a person or extracts biometric identifiers (such as a faceprint) from a video, image, or camera feed, and does not share any recording with a third party for that purpose. A video or image that a user chooses to submit for an assessment is handled as ordinary video content under this Section D, Section 5 (How We Disclose Information), Section 8 (Retention), and Section 10 (Privacy Rights and Choices): it is viewed by authorized instructors and reviewers, stored with our hosting provider, retained for the period stated in Section 8, and deleted when the account is deleted or earlier on request.
Assessment recordings are used only for evaluation, feedback, instructional support, progress tracking, safety or integrity review, and operation of the requested assessment service. They are not used for advertising, public promotion, testimonials, or AI model training unless Keens obtains separate, valid authorization for the additional purpose. Marketing use requires the separate Optional Media and Marketing Consent.
E. Communications
We may collect messages, support requests, survey responses, reports, complaints, instructor communications, parental requests, consent withdrawals, and records necessary to resolve safety, privacy, or account issues.
F. Device, Network, and Usage Information
We and our service providers may automatically collect:
- IP address and approximate location derived from it;
- browser type, device type, operating system, language, and settings;
- device, application, cookie, or session identifiers;
- login time, pages or features used, clicks, errors, and technical performance;
- referring URL and security or fraud signals; and
- upload and playback diagnostics.
G. Information from Others
We may receive information from a parent or guardian, instructor, organization sponsoring access, identity-verification provider, payment processor, authentication provider, or another person authorized to interact with the account.
3. How We Use Information
We may use personal information to:
- Create and administer accounts and enrollments.
- Provide classes, practice tools, assessments, feedback, progress tracking, and customer support.
- Personalize training plans and recommend appropriate content.
- Confirm age, eligibility, parental authority, and consent.
- Process transactions through authorized payment providers.
- Authenticate users and maintain the security and integrity of the Services.
- Detect and address fraud, abuse, account compromise, policy violations, and safety concerns.
- Communicate about the Services, changes, support, and account administration.
- Operate, maintain, troubleshoot, and improve service reliability and accessibility.
- Create aggregated or de-identified analytics where reasonably possible.
- Comply with law, respond to lawful requests, and establish, exercise, or defend legal claims.
- Carry out another purpose described at the time of collection with any consent required by law.
We do not materially expand the use of a child’s information without providing appropriate notice and obtaining a new parental consent when required.
4. Legal Bases Where Required
Where applicable law requires a legal basis, we rely on one or more of the following:
- performance of a contract or steps requested before entering a contract;
- consent, including verifiable parental consent where required;
- compliance with a legal obligation;
- protection of vital interests in an emergency; or
- legitimate interests such as security, service operation, fraud prevention, and improvement, when those interests are not overridden by the individual’s rights.
A user may withdraw consent for future processing at any time where consent is the legal basis. Withdrawal does not make earlier lawful processing unlawful and may affect a feature that genuinely requires the information.
5. How We Disclose Information
We may disclose personal information to:
A. Service Providers
Vendors may process information for hosting, storage, content delivery, authentication, communications, customer support, payments, analytics, security, video processing, transcription, or other operations. They may use the information only under applicable contract and law for authorized services to Keens Academy.
B. Instructors and Authorized Personnel
Authorized instructors, reviewers, employees, and contractors may access information only when reasonably necessary for instruction, evaluation, support, safety, security, or administration and subject to confidentiality and access controls.
C. Legal, Safety, and Rights Protection
We may disclose information when reasonably necessary to comply with law or valid legal process; protect a person from serious harm; investigate fraud, abuse, or security incidents; or establish, exercise, or defend legal rights.
D. Corporate Transactions
Information may be transferred as part of a merger, financing, reorganization, sale of assets, insolvency, or similar transaction, subject to applicable notice and legal requirements.
E. At the Direction of the User or Parent
We may disclose information when the user, or an authorized parent or guardian, directs or validly consents to the disclosure.
Keens Academy does not sell personal information for money. Keens Academy does not use or disclose personal information from children under 13 for targeted advertising or cross-context behavioral advertising. Keens Academy does not publicly post an assessment recording unless a valid, separate media consent specifically authorizes that use.
6. Cookies and Similar Technologies
We may use cookies, local storage, software development kits, and similar technologies to keep users signed in, remember settings, operate uploads and playback, maintain security, prevent fraud, measure technical performance, and understand use of the Services.
Where required, we will request consent before using non-essential technologies. Device or browser controls may permit a user to reject or delete cookies, but disabling necessary technologies may affect operation of the Services.
7. International Data Transfers
Counter Culture US, Inc. is based in the United States. Personal information may be processed in the United States and in other countries where authorized service providers or personnel operate. Privacy laws in those countries may differ from the laws where the user lives.
When applicable law requires safeguards, we will use an appropriate transfer mechanism, such as contractual protections, recognized standard clauses, data-processing agreements, consent where legally valid, or another lawful mechanism. Users may contact us for information about applicable safeguards.
8. Retention
We retain personal information only as long as reasonably necessary for the purposes described in this Policy, including providing the Services, maintaining learning continuity, protecting users and the Services, meeting legal obligations, and resolving disputes.
Unless a different period is required or justified and disclosed, our operating defaults are:
- Incomplete or unsubmitted temporary uploads: up to 30 days.
- Submitted assessment video and audio: during active enrollment and up to 12 months after the account’s last activity, unless deletion is requested earlier or a longer period is separately authorized for a selected Progress Archive.
- Selected Progress Archive recordings: for the period described at opt-in, while the option remains active, subject to withdrawal and applicable deletion rights.
- Scores, instructor feedback, levels, training plans, and progress history: while the account is active and up to 3 years after the last activity, unless deletion is required or requested earlier.
- Customer support and ordinary account records: while needed to provide the Services and generally up to 3 years after account closure or last interaction.
- Security logs: generally up to 12 months, unless a longer period is needed to investigate or address an incident.
- Parental consent, waiver acceptance, transaction, withdrawal, and legal-compliance records: as long as required by law or reasonably necessary to demonstrate compliance and protect legal rights.
A valid deletion request may shorten these periods unless retention is required by law, necessary for security, or needed to establish, exercise, or defend legal claims. Deleted information may remain in access-restricted backups for up to 90 days before being overwritten or securely deleted and will not be restored for ordinary business use.
We review retention practices periodically and delete or de-identify information that is no longer reasonably necessary.
9. Security
We use reasonable administrative, technical, and physical safeguards appropriate to the nature of the information, such as access controls, authentication, encryption in transit where appropriate, logging, vendor controls, staff confidentiality obligations, backup protections, and incident-response procedures.
No method of transmission or storage is completely secure. Users and parents should protect account credentials and contact us promptly if they suspect unauthorized access, disclosure, or loss.
10. Privacy Rights and Choices
Depending on applicable law and location, a user or authorized parent or guardian may have the right to:
- know whether and how we process personal information;
- request access to or a copy of personal information;
- request correction of inaccurate information;
- request deletion;
- obtain a portable copy of certain information;
- restrict or object to certain processing;
- withdraw consent for future processing;
- opt out of certain disclosures, targeted advertising, or profiling where applicable;
- appeal a decision about a privacy request; and
- complain to a relevant data-protection authority.
To make a request, contact [email protected]. We may verify identity, authority, and jurisdiction before acting. An authorized agent may submit a request where permitted by law, but we may require proof of authorization.
Users may opt out of non-essential promotional email by using the unsubscribe link. Service, safety, legal, and account-administration messages may still be sent.
We will not unlawfully discriminate against a person for exercising a privacy right.
11. Children and Parental Controls
Keens Academy may accept users under 13 only through the child-specific onboarding and consent process. Before collecting personal information from a child when parental consent is required, we will provide the parent or legal guardian with the Children’s Privacy Notice and obtain verifiable parental consent using a method reasonably designed to confirm the consenting adult’s identity and authority.
A parent or legal guardian may request to review the child’s personal information, correct it, delete it, refuse further collection or use, or withdraw consent. We may retain limited records necessary to document the request and legal compliance.
We do not condition a child’s participation on disclosing more personal information than is reasonably necessary for the requested activity. If we learn that required parental consent was not obtained, we will take reasonable steps to stop processing and delete the child’s personal information, subject to legal exceptions.
12. Automated and AI-Assisted Features
The Services may use automated or AI-assisted tools to support technical analysis, feedback, recommendations, moderation, security, or service operation. Such outputs may be incomplete or inaccurate and are not medical diagnoses or guarantees of safe or correct performance. These tools work from text, learning records, and the information described in Sections 2.A through 2.C and 2.E; they do not perform facial recognition or biometric analysis (see Section 2.D).
Assessment recordings are not used to train general-purpose or promotional AI models under this Policy. If Keens Academy proposes a materially different training or model-development use, we will provide separate notice and obtain any consent required by law before that use.
Where required by law, users may request information about significant automated processing or human review of a decision that produces legal or similarly significant effects.
13. Third-Party Links and Features
The Services may link to third-party services. A third party’s own privacy policy applies when the third party independently determines how information is used. Parents and users should review those policies before providing information.
14. Changes to This Policy
We may update this Policy to reflect changes in the Services, law, or operations. We will post the updated version and effective date and provide additional notice when required. If a change materially expands the collection, use, or disclosure of a child’s information, we will obtain new parental consent when required.
15. Contact Us
For privacy questions, requests, complaints, or parental controls, contact:
Counter Culture US, Inc. d/b/a Keens Academy
2035 Sunset Lake Road, Suite B-2
Newark, Delaware, United States
Email: [email protected]
Policy Version: 1.0
Effective Date: September 8, 2026