Effective Date: October 26, 2020
We may modify this Policy at any time. All changes will be effective immediately upon posting to the Sites.
If you use any of the Sites, you must comply with our Terms and Conditions (“Terms”).
1. CATEGORIES OF PERSONAL INFORMATION WE COLLECT
We may collect the following categories of information:
Identifiers such as first name, last name, alias, unique personal identifiers, online identifiers including usernames for Social Media, internet protocol address (“IP Address”), account username and password.
Contact Information, including postal address (street address, city, state, postal zip, country), telephone number, and email address.
Customer Records, including bank account number, tax identification number, credit card or debit card number and signature.
Demographic Information, including age, gender, status as a teacher or a student, and veteran or military status.
Commercial Information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Device and Usage Information, including browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement, operating system, platform and device type.
Location Data, through GPS or browser.
Employment Information, including professional or employment-related information from job applicants.
Inferences drawn from any of the information identified in this section to make recommendations based on the consumer’s preferences.
This Policy does not apply to any information that is publicly available.
2. CATEGORIES OF SOURCES
We may collect information from the following categories of sources:
Directly From You. We collect Personal Information that you provide directly to us to use certain features of the Sites, for example, to create online accounts, purchase products or services, contact us via email, phone, or our Contact Us form (where we may retain the content of your message and our response), submit job application materials, receive or request data from us (e.g., catalogs and newsletters), and respond to communications from us (e.g., surveys and promotional offers).
Company Accounts. To create an online account with the Company, you must submit your name and email address, and create a password. This data is used to populate a profile within your account.
Order & Payment Data. When you make a purchase online, we use a third-party payment processor to help us facilitate payment. We do not receive your credit card, debit card or other financial information when you make a payment- such information is provided directly to the payment processor. However, we do receive information about your purchase and your contact information (e.g. name, email address, mailing address, phone number).
Marketing Communications. If you opt-in to receive marketing communications from us, you must submit your name, email address, mailing address, and phone number. We use this data to send you promotional and other electronic and hardcopy communications. We may use third-parties or service providers to deliver communications to you.
Feedback. When you provide comments or feedback about our Sites, the content on the Sites, or our products or services (“Feedback“), we will not treat that Feedback as confidential and we may use that Feedback for any purpose in our sole discretion so long as it does not personally identify you. Feedback will be used without attribution or compensation to you.
Giveaways, Sweepstakes & Contests. We may offer giveaways, sweepstakes or contests. To participate you must submit certain data, which may include your first and last name, email address, phone number, physical address (street address, city, state, postal/zip, country), Instagram name, confirmation that you are over 18 years of age, and other Personal Information. Data collected via giveaways, sweepstakes and contests will be (i) used to contact you with promotional and related communications, (ii) shared with third parties and/or service providers, and (iii) subject to additional terms provided to you at such time.
Business Contracts with Us. When a business contracts directly with us for the purchase of our products or services, we may collect the business contact information of those involved.
Personal Information Collected Automatically. We automatically collect certain information from you when you access our Sites.
Account Activity. We may collect data about how you use (i) your online account, and (ii) the Sites when you are logged into your account. We may combine data automatically collected from you with other Personal Information about you.
What are cookies and web beacons / pixel tags? A cookie is a small text file that our Sites save onto your computer or device when you use the Sites that provides us certain information about your activities. Cookies allow the Sites to remember your actions and preferences and recognize you or your browser. Web beacons / pixel tags are small graphics on a webpage that monitor your activity when viewing a webpage.
- make our Sites function properly;
- provide personalized experiences;
- tailor our interactions with you, including remembering the information that you have already provided to us;
- help with our marketing efforts;
- provide us with valuable data and statistics about the usage and effectiveness of our Sites and to help us improve our Sites; and
- help us improve our services.
What type of information do Cookies collect? The Cookies on our Sites may collect information such as:
- the IP addresses assigned to the computers and other devices you use;
- your internet service provider;
- the device ID number;
- approximate geographic location;
- the Sites’ pages visited or clicked on;
- the date and time you visited the Sites, and the amount of time spent on the Sites;
- your operating system, browser type, search requests, and other similar information;
- the websites you access before and after visiting the Sites, and
- data related to how and when you use the Sites.
We may combine information from Cookies with Personal Information, including data obtained from other sources.
How long do Cookies last? A Cookie can either be a “session” Cookie or a “persistent” Cookie. Session Cookies exist only for so long as you are visiting the applicable Sites and are typically deleted when you exit your web browser. Persistent Cookies exist for a set period of time, for example, up to several months or years. Each time you visit one of the Sites that has implemented a persistent Cookie, the persistent Cookie is renewed and that Cookie will remain active until its predetermined expiration date. You can manually delete persistent Cookies through your browser settings.
Flash cookies differ from other browser cookies regarding the amount and types of data collected and how the data is stored. Your browser will not remove and cannot manage Flash cookies in the same way as other Cookies. To learn about managing your Flash cookie settings, visit the Flash player settings page on Adobe’s website here.
First-party versus third-party Cookies. Cookies may either be “first-party” or “third-party” Cookies. A first-party Cookie allows your web browser to talk to the actual Sites that you are visiting (i.e. this Site). A third-party Cookie allows your web browser to talk to a third-party website, such as the source of an ad that appears on the website you are visiting or a third-party analytics provider. We do not have control over how information gathered by third-party Cookies is used by third parties.
How do you manage Cookies or opt-out? Most browsers automatically accept cookies. You can disable this function by changing your browser settings, but disabling cookies may impact your use and enjoyment of the Sites. Not all features or functions of the Sites may work properly if you disable Cookies. You cannot disable all Cookies, such as Cookies that are essential to the functioning of the Sites.
“Do-Not-Track”. We currently do not respond to “Do Not Track” requests.
Analytics. We use Analytics providers including Google Analytics to collect and process information about your use of the Sites. Google sets cookies on your browser or device, and then your web browser will automatically send information to Google. Google uses this information to provide us with reports that we use to better understand and measure how users interact with our Sites.
Interest-based Advertising. We use third parties and/or service providers to provide interest-based advertising services. These services may serve advertisements on our behalf that are customized based on predictions about your interests generated from your visits to websites (including these Sites) over time and across different websites. The data collected may be associated with your Personal Information. These advertisements may appear on the Sites and on other websites, and may be sent to you via email.
To change your preferences with respect to certain online ads or to obtain more information about ad networks and online behavioral advertising, visit National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Changing your settings with individual browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads. Opting-out of targeted advertising does not opt you out of all ads, just those targeted to you.
Third-Party Sources. We may obtain data about individuals from various third-party companies and public sources and we may combine that data with Personal Information or other data we collect. If we do so, this enhances our existing data about our users, improves our ability to contact you, and enhances our marketing capabilities.
3. PURPOSE FOR COLLECTING PERSONAL INFORMATION
We may use the Personal Information listed above for the following business purposes:
As Stated or Agreed to at the Point of Collection. We may collect and use Personal Information for the purposes stated or agreed-to (or as is obvious) at the point of collection. For example, we use Personal Information to respond to your questions, comments, or complaints. We may also use Personal Information as requested or consented to by you.
Administration. We use Personal Information for administrative purposes, such as managing your accounts, facilitating transactions, to inform our business strategies, to understand the Sites’ demographics and user preferences, for evaluating applications, and managing profiles.
Sites’ Management. We use Personal Information for the Sites’ management, such as troubleshooting problems, improving the content and functionality of the Sites, statistical and other analyses of the Sites, and to customize the Sites to you and our users.
Advertising and Communications. We may use Personal Information to send you promotions or to perform targeted advertising, to notify you of new services, products or programs, to notify you of new features of our Sites, to notify you of changes to our Terms or this Policy, and for other similar communications.
To Protect Our Rights. We may use Personal Information to protect our legal rights or interests, or those of other parties, including to bring a legal action against you or anyone who may be causing harm to us, our Sites, or to other users of the Sites. We may also use Personal Information to seek business, financial or legal advice, and to respond to other legal requests.
4. DISCLOSURE OF PERSONAL INFORMATION
We may share the Personal Information listed above as follows:
Employees and Affiliates. We may share Personal Information with our employees and affiliates who have a need to know the information for our business purposes.
Third-Parties and/or Service Providers. We may share Personal Information with third parties and/or service providers that provide services for us. For example, we may share Personal Information with vendors to help us host and manage the Sites; provide targeted advertising and other marketing; improve the content and functionality of the Sites; perform data analysis and statistical analysis; troubleshoot problems with the Sites; provide payment processing services and online storefronts; provide public relations; provide learning management systems; provide email services; provide data processing; and support or provide the security of the Sites.
Government Officials / Law Enforcement. We will cooperate with law enforcement and other governmental agencies, and may disclose Personal Information: (i) if we believe in good faith we are legally required to disclose that Personal Information, (ii) if we are advised to disclose Personal Information by our legal counsel, or (iii) when necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, the Company or any other party.
Professional Advisors. We may share Personal Information with our professional advisors, such as our attorneys, accountants, financial advisors and business advisors, in their capacity as advisors to the Company.
Change in Ownership. In the event (a) the Company is subject to a change of control, (b) the Sites change ownership, in whole or in part, or (c) of a bankruptcy, receivership or a similar transaction, we may provide Personal Information to the subsequent owner(s), including as part of any due diligence process.
Other. We may share Personal Information with third parties and/or service providers when explicitly requested by or consented to by you, or for the purposes for which you disclosed the Personal Information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).
5. USE AND DISCLOSURE OF DE-IDENTIFIED OR AGGREGATED INFORMATION
The Company may collect, use, share, transfer and otherwise process de-identified and aggregated information that it receives or creates for any purposes in its sole discretion, in compliance with applicable laws. The Company is the sole and exclusive owner of such de-identified and aggregated information, including if the Company de-identifies Personal Information so that it no longer considered Personal Information under applicable laws.
The Sites are not directed at children. We do not knowingly collect Personal Information from children under the age of 13 unless we have appropriate parental consent. If you earn that your child provided us with Personal Information without your consent, please contact us.
7. SOCIAL MEDIA
We are active on social media, including YouTube, Pinterest, Facebook, Instagram, Twitter, LinkedIn and TikTok (“Social Media”). Anything you post on Social Media is public information and will not be treated confidentially. We may post (or re-post) on the Sites and our Social Media pages any comments or content that you post on our Social Media pages.
Your use of Social Media is governed by the privacy policies and terms of the providers that own and operate those websites and not by this Policy. We encourage you to review those policies and terms.
8. DATA SECURITY
We use commercially reasonable technical and organizational measures to help secure Personal Information against loss, misuse, and alteration appropriate to the type of Personal Information processed. If a breach of your Personal Information occurs, we will notify you of the breach if required under applicable law.
NO DATA TRANSMISSION OVER THE INTERNET OR DEVICE CAN BE GUARANTEED TO BE 100% SECURE. WHILE WE STRIVE TO PROTECT PERSONAL INFORMATION, WE DO NOT GUARANTEE THE SECURITY OF PERSONAL INFORMATION AND YOU PROVIDE PERSONAL INFORMATION AT YOUR OWN RISK.
9. ACCESS FROM OUTSIDE THE UNITED STATES
The Sites are intended for consumers within the United States. If you access the Sites from outside the United States, please be aware that Personal Information may be transferred to, stored in, and processed in the United States.
10. THIRD-PARTY WEBSITES
11. TERMS APPLICABLE TO CALIFORNIA RESIDENTS ONLY
This Section 11 provides additional terms that apply to residents of California. In the event of a conflict between this Section and the remainder of this Policy, this Section shall take precedence for California residents. In this Section only, any capitalized terms not defined in this Policy have the meanings set forth in the California Consumer Privacy Act of 2018 (the “CCPA”).
Categories of Personal Information Collected. In the past 12 months we have collected the following categories of Personal Information
- Contact Information
- Customer Records
- Health and Medical Information
- Commercial Information
- Device and Usage Information
- Location Data
- Employment Information
Categories of Personal Information Disclosed for a Business Purpose. In the last 12 months we disclosed the following categories of Personal Information for our Business Purposes:
- Contact Information
- Customer Records
- Commercial Information
- Device and Usage Information
- Location Data
- Employment Information
Your Rights to Access and Deletion. California residents have certain rights under the CCPA, such as the right to request certain information or request deletion of their personal information. Subject to certain limitations such as (a) exceptions permitted by applicable law and (b) verification of your identity, California residents may exercise the following rights with regard to their Personal Information:
Right to Access. You have the right to access any of the following which occurred in the prior 12-month period: (a) the categories of Personal Information we collected from you, (b) the categories of sources from which the Personal Information was collected, (c) the business or commercial purpose for collecting or Selling your Personal Information, (d) the categories of third parties with whom we shared your Personal Information, (e) the specific pieces of Personal Information we collected from you (i.e. “data portability”), and (f) a list of categories of Personal Information we Sold or disclosed for a Business Purpose in the last 12 months.
Right to Deletion. You have a right to request that we delete Personal Information we collected from you. We will comply with such request, and direct our service providers to do the same, subject to certain exceptions permitted by applicable law.
How to Exercise Your Rights of Access and Deletion. To exercise your California rights described in this Section, you may submit your request to us by contacting us at any of the following:
Verifying Your Request. In order to verify your request, you must provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information, and you must describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to your request.
When we receive your request to exercise your rights under the CCPA we will: (a) acknowledge receipt of your request; (b) try to match the information you provide in making the request with information we already maintain about you; (c) if required to verify your identity, ask you to provide additional information, including personal information; (d) consider various factors when determining how to verify your identity, such as the sensitivity and value of the data, the risk of harm, the likelihood of fraud, etc.
We will only use personal information we collect during the verification process for the purpose of verifying your identity. If you maintain an account with us, we may use that account to respond to your request and/or verify your identity. If we are unable to verify your identity as required by applicable laws and regulations, we will decline to comply with your request, and let you know why.
When We Will Respond. We will try to respond to your request for access or deletion within 45 days. If we require additional time, we will inform you of the reason and extension period. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. For data portability requests, we will select a format to provide your Personal Information to you. We may charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded.
Your Rights to Opt-Out of the Sale of Personal Information. California residents have the right to opt out of the Sale of their Personal Information. In the last 12 months we have not Sold your Personal Information and we currently do not Sell Personal Information.
Non-Discrimination. California residents have the right to not receive discriminatory treatment for exercising any of their rights under the CCPA.
Who May Exercise Your Rights? You may only make a request to exercise your rights on behalf of yourself. You also have a right to submit requests to exercise your rights under the CCPA through an authorized agent. An authorized agent must be registered with the Secretary of State in California to conduct business in California. If you choose to use an authorized agent, you must (a) provide signed permission to that authorized agent to submit requests on your behalf, (b) verify your identity directly with the Company, and (c) directly confirm with Company that you granted permission to the authorized agent to submit the request on your behalf. For clarity, you are required to verify the identity of both yourself and the authorized agent.
We may deny a request from an authorized agent if we do not have proof that they are authorized by you to act on your behalf.
Shine the Light. Pursuant to California Civil Code Section 1798.83, if you are a California resident, you have the right to obtain: (a) a list of all third parties to whom we may have disclosed your Personal Information within the past year for direct marketing purposes, and (b) a description of the categories of Personal Information disclosed, by contacting us per the “Contact Us” Section below.
12. CONTACT US
If you have any questions you may contact us as set forth below: