(Updated & Effective January 13, 2024)
A. INFORMATION WE COLLECT
We typically collect two kinds of information about you when you use our Services: (a) information that you provide that personally identifies you; and (b) information that does not personally identify you, but that we automatically collect or that you provide us.
(1) Personally Identifiable Information: Our definition of personally identifiable information includes any information that may be used to specifically identify or contact you, such as your name, mail address, phone number, etc. As a general policy, we do not automatically collect your personally identifiable information when you visit our Website. In certain circumstances, we may request, allow or otherwise provide you an opportunity to submit your personally identifiable information in connection with a feature, program, promotion or some other aspect of our Services. For instance, you may: (a) provide your name, mail/shipping address, email address, credit card number and phone number when registering or in connection with a contest entry; (b) provide certain demographic information about you (e.g., age, gender, purchase preference, usage frequency, etc.) when using our Services or participating in a survey or poll; or (c) post a general comment and/or recommendation on our Website or through our Applications.Whether or not you provide this information is your choice; however, in many instances this type of information is required to participate in the particular activity, realize a benefit we may offer, or gain access to certain content or features available through our Services.
(2) Non-Personally Identifiable Information: Our definition of non-personally identifiable information is any information that does not personally identify you. Non-personally identifiable information can include certain personally identifiable information that has been de-identified; that is, information that has been rendered anonymous. We obtain non-personally identifiable information about you from information that you provide us, either separately or together with your personally identifiable information. We also automatically collect certain non-personally identifiable information from you when you access our Services through your Equipment. This information can include, among other things, your mobile device, other applications or software you are using, wireless carrier, IP addresses, the type of browser you are using (e.g., Internet Explorer, Firefox, Safari, Opera, etc.), the third party website from which your visit originated, the operating system you are using (e.g., Vista, Windows XP, Mac OS, Android, iPhone, etc.), the domain name of your Internet service provider (e.g., CenturyLink, Google, Cox, etc.), the search terms you use; and how much you use our Services.
Location Information: When you use our Services, particularly our Application(s), we may automatically collect certain Equipment (mobile device) specific information. This includes the general or specific location of your Equipment through GPS, Bluetooth or WiFi signals. Before we collect or send location-specific information, it is our practice to ask for your consent. In some instances, your operating system may not allow you to install an Application without giving us consent. In all instances, you may withdraw your consent by disabling location features for your Equipment – the Application will still work though certain location features (e.g., Store Locator) may not function.
B. HOW WE USE & SHARE THE INFORMATION COLLECTED
(1) Personally Identifiable Information: The personally identifiable information you submit to us is generally used to carry out your requests, respond to your inquiries, better serve you, or in other ways naturally associated with the circumstances in which you provided the information. We may also use this information to later contact you for a variety of reasons, such as customer service, providing you promotional information for our products or those of our parent company, subsidiaries or other affiliated companies (“affiliated companies”), or to communicate with you about content or other information you have posted or shared with us via our Services. You may opt-out from receiving future promotional information from us or our affiliated companies, or direct that we not share your information with any affiliated companies, as set forth below.
In certain instances we may also share your personally identifiable information with third parties performing functions on our behalf (or on behalf of our affiliated companies) or accessing the Service – e.g., vendors that operate our website store/shop, process credit card orders, administer our promotions, provide us marketing or promotional assistance, analyze our data, assist us with customer service, etc. These third parties agree to use this information, and we share information with them, only to carry out our requests or provide Services. In addition, we may share your personally identifiable information with participating sponsors to a program or promotion (e.g., a sweepstakes or contest) you enter via our Services and certain co-promotional partners and others with whom we have marketing or other relationships.
In certain instances we may also share your personally identifiable information with third parties you have selected to offer you services or promotions (e.g. subscriptions to newsletters, etc.). These third parties agree to use this information, and we share information with them, to provide services and promotions to you.
(2) Non-Personally Identifiable Information: We use non-personally identifiable information in a variety of ways. For example, we may use non-personally identifiable information to evaluate use of and improve our Services (e.g., visits to our Website, use of Data Room AI solutions, etc.), track purchases, gauge coupon redemption rates, understand customer needs and trends, evaluate and analyze learner progress or performance, carry out targeted promotional activities, and to improve our services. We may use your non-personally identifiable information by itself or aggregate it with information we have obtained from other customers or other sources. We may, among other things, share your non-personally identifiable information with our affiliated companies, allow third parties to collect such information directly from you, and/or sell the non-personally identifiable information to third parties to achieve these and any other business objectives (e.g., generate revenue, form alliances, anonymously participate in education development studies etc.). However, it is important to remember that your non-personally identifiable information (whether standing alone or combined with other non-personally identifiable information) is anonymous information that does not personally identify you.
C. COOKIES AND PREFERENCE BASED ADVERTISING
(1) Cookies and Web Beacons: We automatically receive and store certain types of non-personally identifiable information whenever you interact with us. For example, like many websites, we use "cookies" and "web beacons" (also called “clear gifs” or “pixel tags”) and embedded scripts to obtain certain types of information when you use or access our Services. "Cookies" are small files that we transfer to your Equipment’s hard drive, memory or web browser to enable our systems to recognize your browser or Equipment and to provide convenience and other features to you. "Web beacons" are tiny graphics with a unique identifier, similar in function to cookies, and may be used to track the online movements of users, when an email has been opened, and to provide other information.
Examples of the information we collect and analyze in this manner include the Internet Protocol (IP) address used to connect your Equipment to the Internet; computer and connection information such as browser type and version, operating system, and platform; your activities on our Website, including the products or services you viewed or searched for, as well as the URL you come from and go to next (whether this URL is on our site or not); and cookie number. It is important to note that the cookies and web beacons that we use do not contain, and are not tied to, and are not used to automatically collect any personally identifiable information about you.
Opting Out: If you do not wish to participate in preference-based advertising via these third-party advertising networks, go to www.aboutads.info and follow the simple opt-out process. A couple of important notes about this opt-out tool: (1) it includes all the advertising networks that we may work with, but also many that we do not work with; and (2) it may rely on cookies to ensure that a given advertising network does not collect information about you (“Opt-out Cookies”) – an explanation of how Opt-out Cookies work can be found on www.aboutads.info. Therefore, if you use different Equipment, change web browser or delete these Opt-out Cookies, you will need to perform the opt-out task again.
(3) Do Not Track Features: Certain browsers may offer you the option of providing notice to websites that you do not wish for your online activities to be tracked for preference-based advertising purposes (“DNT Notice”). Some browsers are, by default, set to provide a DNT Notice, whether or not that reflects your preference. Unfortunately, given how preference-based advertising works, DNT Notices may not be effective in communicating your preferences. For this and a variety of other reasons, with respect to our Website, we do not take any action based on browser based DNT Notices. Rather, if you do not wish to participate in preference-based advertising activities, you should follow the simple opt-out process identified above.
D. OTHER USES & INFORMATION
(1) IP Addresses: An IP address is a number that is automatically assigned to your Equipment whenever you access the Internet. Web servers (computers that "serve up" web pages) automatically identify your Equipment by its IP address. When visitors request pages from our Website, our servers typically log their IP addresses. We collect IP addresses for purposes of system administration, to report non-personal aggregate information to others, and to track the use of our Services. IP addresses are considered non-personally identifiable information and may also be shared as provided above. It is not our practice to link IP addresses to anything personally identifiable; that is, the visitor's session will be logged, but the visitor remains anonymous to us. However, we reserve the right to use IP addresses to identify a visitor at the request of the visitor or when we feel it is necessary to enforce compliance with our Service rules or to: (a) fulfill a government request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our Services, or other users; or (d) in an emergency to protect the health and safety of our customers or the general public.
(2) Social Networks: We may offer you the ability to create or login to your account with us through accounts you may have with various social network platforms, such as Google, Facebook, Instagram, LInkedIn, or X (formerly Twitter) (each, a “Social Network Account”). To do so, you may be required to provide, or allow our Services to access, your Social Network Account login information. By granting us access to your Social Network Account, you understand and agree that we may access, make available and store any content that you have provided to and stored in your Social Network Account (e.g., friends, mutual friends, contacts, etc.). We may make this information available on or through our Services and to our users. You may be able to restrict what information is shared and how it is used through privacy and other settings. Also, depending on the privacy settings you have set in your Social Network Account, personally identifiable information may be shared with us and made available through our Services and to our users.
(3) Email Communications: If you send us an email with questions or comments, we may use your personally identifiable information to respond to your questions or comments, and we may save your questions or comments for future reference. For security reasons, we do not recommend that you send non-public personal information, such as passwords, social security numbers, or bank account information, to us by email. We may send you emails for a variety of reasons – e.g., emails in response to your request for a particular service or your registration for a feature that involves email communications, emails that relate to purchases you have made with us (e.g., product updates, customer support, etc.), informational emails about our other products, services or events, or when you consent to being contacted by email for a particular purpose. In certain instances, we may provide you with the option to set your preferences for receiving email communications from us; that is, agree to some communications but not others. ￼You may "opt out" of receiving future commercial email communications from us by clicking the "unsubscribe" link included at the bottom of most emails we send, or as provided below; provided, however, we reserve the right to send you transactional emails such as order confirmations and customer service communications.
(4) Transfer of Assets: As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or all (or substantially all) of our assets, the personally identifiable information and non-personally identifiable information we have about you will be transferred to and used by this acquiring entity, though we will take reasonable steps to ensure that your preferences are followed. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.
(6) Your California Privacy Rights: Residents of the State of California, under certain provisions of the California Civil Code, have the right to request from companies conducting business in California a list of all third parties to which the company has disclosed certain personally identifiable information as defined under California law during the preceding year for third party direct marketing purposes. You are limited to one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for our response. You may request the information in writing as provided in Section I below.
E. PUBLIC FORUMS
F. KEEPING YOUR INFORMATION SECURE
We have implemented security measures we consider reasonable and appropriate to protect against the loss, misuse and alteration of the information under our control (e.g., where appropriate, implementing firewalls, encryption, etc.). Please be advised, however, that while we strive to protect your Personally Identifiable Information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online or through our Services, and are not responsible for the theft, destruction, or inadvertent disclosure of your Personally Identifiable Information. In the unfortunate event that your "Personally Identifiable Information" (as the term or similar terms are defined by any applicable law requiring notice upon a security breach) is compromised, we may notify you by e-mail (at our sole and absolute discretion) to the last e-mail address you have provided us in the most expedient time reasonable under the circumstances; provided, however, delays in notification may occur while we take necessary measures to determine the scope of the breach and restore reasonable integrity to the system as well as for the legitimate needs of law enforcement if notification would impede a criminal investigation. From time to time we evaluate new technology for protecting information, and when appropriate, we upgrade our information security systems.
G. OTHER SITES/LINKS
Our Services may link to or contain links to third-party websites that we do not control or maintain, such as in connection with purchasing products we may recommend or reference via our Services and/or advertisements you may see while using our Services. We are not responsible for the privacy practices employed by any third-party website. We encourage you to read the privacy statements of all third-party websites before submitting any Personally Identifiable Information through these websites.
H. CONTACT & OPT-OUT INFORMATION
We will respond to your request and, if applicable and appropriate, make the requested change in our active databases as soon as reasonably practicable. Please note that we may not be able to fulfill certain requests while allowing you access to certain benefits and features of our Website and/or Application.
I. SOLE STATEMENT