Last modified: April 21st , 2021

CodeMonkey Privacy Policy

PRIVACY POLICY

PRIVACY POLICY FOR INFORMATION COLLECTED BY CODEMONKEY STUDIOS LTD. AND ITS WEBSITES: CODEMONKEY.COM, APP.CODEMONKEY.COM, PLAYCODEMONKEY.COM, CODEMONKEY.CO.IL, CM-STUDIOS.COM, CMONKEY-P.HEROKUAPP.COM, CODEMONKEY JR, APPS AND SERVICES.

Because your privacy is important to us, CodeMonkey      Solutions Ltd. (“we”, “us”, “our”) operates by the principles described herein. We have created this privacy policy (“Privacy Policy”) in order to describe to you our practices regarding the information that we collect and how we use it. By accessing and/or using our websites that post this Privacy Policy, including CODEMONKEY.COM, APP.CODEMONKEY.COM, PLAYCODEMONKEY.COM, CODEMONKEY.CO.IL, CM-STUDIOS.COM, CMONKEY-P.HEROKUAPP.COM, CODEMONKEY JR. (each, a “Website” and collectively, the “Websites”), our mobile applications (“Apps”) and/or our services from any browser, application, or device you are using (collectively, the “Services”), and/or accepting the Terms of Service (which you can review here), you consent to the collection and use of your information as we have outlined in this Privacy Policy. Capitalized terms used and not otherwise defined herein shall have the meanings given to them under the Terms of Service.  For additional information on how we process your personal information if you are an EU individual, see “Additional Information for EU Individuals” below.  For additional information on how we process your personal information if you are a California resident, see “Additional Information for California Residents” below.

1. THE INFORMATION WE COLLECT FROM OR ABOUT PARENTS, TEACHERS AND OTHER USERS OF OUR WEBSITES AND SERVICES
2. HOW WE USE AND SHARE INFORMATION THAT WE COLLECT FROM OR ABOUT PARENTS, TEACHERS AND USERS OF OUR WEBSITES AND SERVICES
3. CHILDREN’S INFORMATION
4. COOKIES AND OTHER TECHNOLOGIES
5. LINKS TO OTHER WEBSITES
6. INFORMATION SECURITY
7. ACCESS TO YOUR PERSONAL INFORMATION AND PARENTAL ACCESS RIGHTS
8. CHANGES TO THIS PRIVACY POLICY
9. GOVERNING LAW
10. CONTACT US
11. ADDITIONAL INFORMATION FOR EU INDIVIDUALS
12. ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

We collect information about you directly from you, as well as automatically through your use of our Websites or Services. The information we collect from you will depend on how you interact with us.  When we say “Personal Information” in this Privacy Policy, we mean information that can reasonably be used, alone or in combination with other reasonably available information, to identify a specific individual. Any information combined with Personal Information will be treated as Personal Information.  You are not required to provide us with any information, although we may be unable to provide the Services to you without your information.

We do not knowingly collect Personal Information from children under the age of 13 without appropriate consent.  When we describe how we collect, use and share Personal Information in Sections 1 and 2 below, we are describing how we collect, use and share your information if you are a parent or teacher of one of our users, or another Website visitor over the age of 13     .  For information about how we collect, use and share information from children, please see  “Children’s Information” below.

1. THE INFORMATION WE COLLECT FROM OR ABOUT PARENTS, TEACHERS, AND OTHER USERS OF OUR WEBSITES AND SERVICES

If you are a parent or teacher of one of our users, or another visitor to our Website or user of our Services over the age of 13, we collect the following information from or about you:

INFORMATION YOU PROVIDE DIRECTLY

  • Registration and Payment. We collect Personal Information through your registration for and/or use of the Services. For example, during the registration process we will ask you for your name and the name of your institution or organization, your e-mail address, the physical address of your institution or organization, the phone number of your institution or organization, and other information related to the Services. We may collect billing and account information for credit cards, payment cards or other payment systems from you if you purchase a paid version of our Services and we may share this information with our third party billing and payment processors. We do not store credit card or payment card numbers as billing and processing are handled by service providers retained by CodeMonkey, such as billing and payment processors.  Your use of such services are subject to the terms of service and privacy policy of such service providers.
  • Authentication Details. In order to create an account, we collect from a parent a child’s username and display name (which cannot contain full name or an email address), and a password. In addition, we request from the parent the child’s age for our internal analytics purposes; although parents are not required to provide this information. 
  • Customer Services and Other Communications. We collect Personal Information when you contact our customer support, send us other communications, or sign up for newsletters or special offers.
  • User Generated Content. Our Websites offer a blog and community forums to allow you to learn more about us. These areas of the Websites are intended for parents and teachers. You are not required to share Personal Information, but if you choose to do so, it may be published, read, collected, and used by others who access the blog or forums. We are not responsible for any Personal Information you choose to submit in blogs or any other publicly accessible service or area of our Websites. To request removal of your Personal Information from our blog or community forums, contact us via email at privacy@codemonkey.com.

Testimonials.  We may post our own customers’ testimonials on our Websites or Apps, which may contain Personal Information.  In some cases, parents may provide testimonials regarding their child’s experience on our Website or App. We will obtain a customer’s consent to post the customer’s (or the customer’s child’s) name, picture and testimonial (unless such information was already made public by the customer).

INFORMATION WE COLLECT AUTOMATICALLY

We automatically collect the following information about your use of our Website or Services through cookies, web beacons, and other technologies: your IP address, web pages that you visit, referring, website, types of browsers, operating systems, and/or devices you are using, settings, information regarding your mobile network (such as carrier name, phone number), other data normally stored in website logs, site usage, and whether you opened emails you received from us. Please see the section “Cookies and Other Technologies” below for more information.

2. HOW WE USE AND SHARE INFORMATION THAT WE COLLECT FROM OR ABOUT PARENTS, TEACHERS AND OTHER USERS OF OUR WEBSITES AND SERVICES

Except in a business transaction as described herein, we never sell or rent your personal information.

If you are a parent or teacher of one of our users, or another visitor to our Website or user of our Services over the age of 13, we may use and share your information in the following ways:

  • Transactional Purposes. We use and share your information to provide the Services, to audit and improve our Services, and in accordance with the uses set forth in our Terms of Service.
  • Promotions and Information. We may occasionally inform you of new features, functionality, services and products, and other promotions from CodeMonkey or our affiliates, as well as send you periodic updates, tips and newsletters. You may opt-out of receiving these communications from us by following the unsubscribe instructions included in each communication. Note that regardless of your election, we may continue sending you notices to update you on revisions made to this Privacy Policy or to our Terms of Service.
  • Affiliates. We may share information with our parent company or other affiliates.
  • Service Providers. We may use and share information with our service providers, including those that help us operate our Websites, Apps and Services (e.g., cloud services providers, email distribution service providers, billing and payment processors, and other similar service providers). When we use such service providers, we restrict them from using or disclosing your information, except as required to perform services on our behalf or to comply with legal requirements. Personal Information of our users will not be shared with third parties for marketing purposes.
  • Legal and Compliance Purposes. We may share information with third parties when complying with legal process, to protect our intellectual property and other legal rights, to prevent fraud or imminent harm, and secure of our Services. We reserve the right to disclose your information as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a law enforcement order, such as a search warrant, judicial proceeding, or court order. We may also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our Terms of Service.
  • Aggregated or Anonymous Data. We may use and disclose anonymous or aggregated information about our users to potential business partners, investors, or the public, or use it for research or analytics purposes.
  • Business Transactions. We may share Personal Information with our parent, subsidiaries and affiliates, and investors primarily for business and operational purposes so long as any recipient agrees to comply with this Privacy Policy and applicable law with regard to such Personal Information. In the event that CodeMonkey goes through a business transaction, such as a merger, acquisition by another company, or sale of all or a portion of its assets, bankruptcy, or other corporate change, including, without limitation, during the course of any due diligence process, your information, including Personal Information, will likely be among the assets shared and transferred. You will be notified via email and/or a prominent notice on the Services of any completed change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information. This Privacy Policy will become binding upon the new owner of the information until amended.

Except as described herein, we do not disclose your information or share it with third parties.

We will retain your information for as long as your account is active or as needed to provide our Services. You may cancel your account at any time via the interface of the Services. If you encounter any problem in cancelling your account and you wish that we no longer use or hold your information, please contact us via privacy@codemonkey.com. When you send an email or other communication to CodeMonkey, we may retain those communications in order to process and respond to your requests and improve our Services. Please do not send us any communication containing confidential information. Since we are not able to evaluate whether such communication contains confidential information or not, we will use the information in accordance with this Privacy Policy, but we will not be in a position to protect your information as confidential.

3. CHILDREN’S INFORMATION

As stated above, you must be at least 13 years old to independently sign up for our Services. We do not knowingly collect Personal Information directly from visitors under the age of 13. We only collect Personal Information through our Services from visitors under 13 where we have received confirmation that the student’s school and/or teacher obtained the required consent for that student to use our Services and disclose the Personal Information, or where the parent of a child has signed the child up to use the Services and provided the necessary consent. If you believe that we may have unintentionally collected Personal Information from a child under the age of 13, please contact us immediately at privacy@codemonkey.com.

The Children’s Online Privacy Protection Act (“COPPA”) requires that we obtain parental consent before knowingly collecting Personally Identifiable Information (as defined under COPPA, “PII”) online from children who are under the age of 13. To comply with COPPA, we adhere to the following practices:

  • You must be at least 13 years old in order to independently gain access to and join our Services. If you are under 13 years old, to use our Services, your parent or guardian needs to create an account for you or you need to have a classroom code from your teacher and join a classroom.
  • We do not knowingly or intentionally collect or solicit PII from children under the age of 13 through our Services unless we have received consent (via our Services and in accordance with our Terms of Service) from the child’s parent or guardian or in case of an educational institution, from the school administrator and/or teacher. As described in more detail above, ordinarily, we collect a child’s username and display name (which cannot contain full name or an email address), a password, and the child’s age. We also collect data showing child’s usage of the Services and progress.
  • Teachers can enable the Game Builder feature. Although this feature is not designed or intended for children to upload personal information, it could potentially allow children to upload images, descriptions, and welcome messages. This activity can only happen after the teacher has provided appropriate consent and affirmatively enabled the feature for the class. Outside the classroom setting, the Game Builder is pre-screened to remove PII.
  • We do not sell any PII of children under the age of 13 to any third party. We may share children’s PII with service providers, who process this information on our behalf to support our internal operations.
  • A parent, guardian, school administrator, or teacher, as applicable, can view, edit or delete all information associated with a child’s account, which is connected to that grown-up’s account through their dashboard, by clicking “my account” or by accessing the “classroom” (if the grown-up is a teacher).
  • We do not require children under 13 to disclose more information than is reasonably necessary to participate in our Services, and we do not retain PII from children under 13 years of age longer than is reasonably necessary in order to fulfill the purpose for which it was collected.
  • As a parent of a child under the age of 13, you have parental access rights outlined in section 7 of this Privacy Policy.

You are not required to provide us with any information about children under 13, although we may be unable to provide the Services without that information.    

We collect the following non-personal information from children as described in more detail below:

  • The data we collect about children’s activity on our site is linked back to their parents’ account for tracking purposes, so parents can see their children’s progress in the different courses. Parents can see the percentage of each course completion, how many courses were started, the total number of solutions submitted by the child, the projects created, amount of time spent on site daily, and the level of proficiency reached in each coding concept.
  • Information We Collect Automatically. We automatically collect the following information from children who use our Website or Services through cookies, web beacons, and other technologies: IP address, web pages that they visit, referring, website, types of browsers, operating systems, and/or devices they are using, settings, information regarding their mobile network (such as carrier name), other data normally stored in website logs, site usage. Please see the section “Cookies and Other Technologies” below for more information.

We use and share the information we collect from children for the following purposes:

  • Transactional Purposes. We use and share your information to provide the Services, to audit and improve our Services, and in accordance with the uses set forth in our Terms of Service.
  • Affiliates. We may share information with our parent company or other affiliates.
  • Service Providers. We may use and share information with our service providers, including those that help us operate our Websites, Apps and Services (e.g., cloud services providers, and other similar service providers). When we use such service providers, we restrict them from using or disclosing your information, except as required to perform services on our behalf or to comply with legal requirements. Personal Information of our users will not be shared with third parties for marketing purposes.
  • Legal and Compliance Purposes. We may share information with third parties when complying with legal process, to protect our intellectual property and other legal rights, to prevent fraud or imminent harm, and secure of our Services. We reserve the right to disclose information as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a law enforcement order, such as a search warrant, judicial proceeding, or court order. We may also retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our Terms of Service.
  • Aggregated or Anonymous Data. We may use and disclose anonymous or aggregated information about our users to potential business partners, investors, or the public, or use it for research or analytics purposes.
  • Business Transactions. We may share Personal Information with our parent, subsidiaries and affiliates, and investors primarily for business and operational purposes so long as any recipient agrees to comply with this Privacy Policy and applicable law with regard to such Personal Information. In the event that CodeMonkey goes through a business transaction, such as a merger, acquisition by another company, or sale of all or a portion of its assets, bankruptcy, or other corporate change, including, without limitation, during the course of any due diligence process, a user’s information, including Personal Information, will likely be among the assets shared and transferred. Users will be notified via email and/or a prominent notice on the Services of any completed change in ownership or uses of their Personal Information, as well as any choices they may have regarding their Personal Information. This Privacy Policy will become binding upon the new owner of the information until amended.

4. COOKIES AND OTHER TECHNOLOGIES

COOKIES

Like many other websites and apps, we use “cookies” (a small file sent to your computer by a website or device to allow the website or app to store information which uniquely identifies you) or other similar software to collect data in order to assist our users and provide them with a more personal experience when visiting our Websites or Apps. For example, cookies help our systems recognize you if you return to our Services shortly after exiting them.      You can always disable cookies in your browser’s or device’s settings, but please note that if you do so, some (or all) of the features and functionality of our Services may not be available to you.

DO NOT TRACK

Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed above.

ANALYTICS

We use automated devices and applications, such as Google Analytics, to evaluate usage of our Websites, and, to the extent permitted, our Services. We also may use other analytic means to evaluate our Websites and Services. We use these tools to help us improve our Websites’ and Services’ performance and user experiences. The entities operating these tools may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services in accordance with their own privacy policies. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy. You can also download the Google Analytics Opt-out Browser Add-on to prevent your data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

5. LINKS TO OTHER WEBSITES

Our Websites and/or Apps may include links to other websites and/or apps whose privacy practices may differ from our own practices. For example, community pages may be available to users in a private group on social media platforms such as Facebook.  If you submit Personal Information to any of those sites, including the community forum, your information is subject to the privacy statements of those sites. We encourage you to carefully read the privacy statement of any website you visit. We store the information we collect with Amazon Web Services (“AWS”) and we encourage you to review the AWS Terms of Service and Privacy Policy, as we will not be responsible for what AWS does with the information.

6. INFORMATION SECURITY

We take information security very seriously. We use industry customary security measures designed to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These measures include internal reviews of our data collection, storage and processing practices and security measures. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee absolute security.

We restrict internal access to Personal Information to our employees, contractors and agents who need to know that information in order to operate, develop or improve our Services. These individuals are bound by confidentiality obligations and we require all of them to agree to use your Personal Information solely for the purpose for which we provided it to them and in accordance with our Privacy Policy.

In the event that we become aware of a data breach impacting your Personal Information, we will provide notification in compliance with all applicable laws. For example, we may post a notice on our homepage or elsewhere on the Services, and may send an email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

We have procedures in place that are designed to stop threats that may expose Personal Information, restore Services to full functionality, and document and take proactive steps to prevent the incident from happening again. We will also preserve necessary evidence for investigation by security professionals and law enforcement as appropriate. In the unlikely event of an unauthorized disclosure of records, we will follow our security incident response procedures, which articulate how to report the problem to internal and external stakeholders, including individuals and, if applicable, law enforcement personnel. Our process includes investigating who may have been impacted and the data that may have been accessed, informing affected customers, where required, and taking steps to prevent the incident from happening again as appropriate.

If you have any questions about security on our Services, you can email us at privacy@codemonkey.com.

7. ACCESS TO YOUR PERSONAL INFORMATION AND PARENTAL ACCESS RIGHTS

To make any requests for access, changes to your child’s account,      the removal of Personal Information collected about you or your child from our Websites or Services (as applicable), or to request that we stop the further collection or use of your or your child’s Personal Information in connection with the Websites or Services (as applicable), please contact us at privacy@codemonkey.com. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Websites for a period of time.

8. CHANGES TO THIS PRIVACY POLICY

We reserve the right to change this Privacy Policy from time to time, so please review it frequently. If we make material changes to this Privacy Policy, and you are a registered user of the Services, we will notify you by email. We will obtain prior parental consent if any changes we make to this Privacy Policy affect users under the age of 13 in a way that requires such consent under COPPA or other applicable law.

9. GOVERNING LAW

This Privacy Policy shall be construed in accordance with and governed for all purposes by the substantive laws of the State of Israel without regard to conflicts of law provisions. You agree that any claim or dispute you may have against the Company and its affiliates, directors, officers, employees and representatives must be resolved by a court located in Tel-Aviv, Israel, and waive any jurisdictional, venue or inconvenient forum objections to such courts.

10. CONTACT US

If you have any question about our security on our Services, our Privacy Policy or privacy practices, please contact us using the following information and we will use commercially reasonable efforts to promptly respond:

privacy@codemonkey.com

CodeMonkey Studios Ltd. 2345 Yale St. 1st Floor Palo Alto, CA 94306, USA

1-888-299-3294

11. ADDITIONAL INFORMATION FOR EU INDIVIDUALS

LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION UNDER GENERAL DATA PROTECTION REGULATION (“GDPR”)

If you are from the European Economic Area (EEA), CodeMonkey Studios Ltd.’s legal basis under GDPR for collecting and using the Personal Information described in this Privacy Policy depends on the Personal Information we collect and the specific context in which we collect it.

CodeMonkey Studios Ltd. may process your Personal Information because:

  • We need to perform a contract with you;
  • You have given us permission to do so;
  • The processing is in our legitimate interests and is not overridden by your rights; or
  • To comply with any applicable law.

More specifically, we process your Personal Information on the following legal bases:

Processing purpose (including sharing for such purposes as described above)Legal basis

 

To provide the Services

Processing is necessary to provide the Services or to take steps that you request prior to requesting the Services.
To communicate with you about the Services
To send you marketing communications
For research and development
To create aggregated or anonymous data for analytics
For security, compliance, fraud prevention and safety
Business transfers
These processing activities constitute our legitimate interests.  We do not use your Personal Information for activities where your data protection interests override these legitimate interests (unless we have your consent or are otherwise required or permitted to by law).

 

 

To comply with law

Processing is necessary to comply with our legal obligations.

 

With your consent

Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated at the time consent is requested.

Please note the following regarding our data processing activities:

  • In situations where we obtain your Personal Information from a source other than you, we process your data on the basis of legitimate interests, until the earlier of (a) the point at which you provide your consent; or (b) the point at which you ask us to stop processing your data on the basis of our legitimate interests;
  • We will archive information about your use of our Services, even after you withdraw your consent to our processing of your data. This information will only be used in very limited circumstances, such as for defending legal claims relating to contracts we have with you or a third party and retention for audit purposes relating to commercial contracts; and
  • We will use information relating to your use of our Services for statistical analysis and research purposes, however we delete your name and email address from such information before we do so.

YOUR DATA PROTECTION RIGHTS UNDER THE GDPR

If you are a resident of the European Economic Area (EEA), you may have certain data protection rights under the GDPR. CodeMonkey Studios Ltd. aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information. In certain circumstances, you have the following data protection rights:

  • The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Information directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
  • The right of rectification. You have the right to have your Personal Information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your Personal Information.
  • The right of restriction. You have the right to request that we restrict the processing of your Personal Information.
  • The right to data portability. You have the right to be provided with a copy of the Personal Information we have on you in a structured, machine-readable and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where CodeMonkey Studios Ltd. relied on your consent to process your Personal Information.

You may send us these requests by emailing us at privacy@codemonkey.com using the email associated with your account.  We may request information from you to help us confirm your identity and process your request. Applicable law may require or permit us to reject part or all of your request.  If we reject your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your Personal Information or response to your requests regarding your Personal Information, you may contact us as described here or submit a complaint to the data protection regulator in your jurisdiction.  You can find your data protection regulator here. 

CROSS-BORDER DATA TRANSFER

In the event that we transfer your Personal Information out of the EEA to countries not deemed by the European Commission to provide an adequate level of protection for personal information, the transfer will be based on safeguards recognized by the European Commission as providing adequate protection, where required by EU data protection legislation.  Please contact us to request further information on the specific mechanism used by us when transferring your personal information out of the EEA.

12. ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

If you are a resident of the state of California, you may have certain data protection rights under the California Consumer Privacy Act of 2018 (“CCPA”). CodeMonkey Studios Ltd. aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information.  This section describes how we collect, use and share Personal Information of California residents subject to the CCPA in operating our business, and their rights with respect to that Personal Information.  For purposes of this section, “Personal Information” has the meaning given in the CCPA, but does not include information exempted from the scope of the CCPA.

PERSONAL INFORMATION THAT WE COLLECT USE AND SHARE

The chart below summarizes how we collect, use and share Personal Information by reference to the categories specified in the CCPA, and describes our practices during the 12 months preceding the effective date of this Privacy Policy. Categories in the chart refer to the categories described above in the general section of this Privacy Policy.

We have not sold your Personal Information in the preceding 12 months.

Category of personal information (PI)

PI we collect

Source of PI

Business/
commercial purpose for collection

Categories of other entities to whom we “disclose” PI for a business purpose

Categories of third parties to whom we “sell” PI

Identifiers

●        Contact data

●        Identity data

●        Data about others

●        You

●        Public sources

●        Business partners

●        Service delivery

●        Research & development

●         Marketing

●         Compliance & Operations

●         Aggregated or anonymous data for analytics

●         Security, fraud protection, and safety

●         Business transfers

 

●        Affiliates

●        Professional advisors

●        Authorities and others

●        Business transferees

 

None

Financial Information

●        Financial data

●        You

●        Service Delivery

●        Compliance & Operations

●        Aggregated or anonymous data for analytics

●        Security, fraud protection, and safety

●        Business transfers

 

●        Affiliates

●        Professional advisors

●        Authorities and others

●        Business transferees

None

Online Identifiers

●        Device data

●        System data

●        Network data

●        Identity data

●        Automatic collection

●        Service Delivery

●        Research & development

●        Marketing

●        Compliance & Operations

●        Aggregated or anonymous data for analytics

●        Security, fraud protection, and safety

●        Business transfers

 

●        Affiliates

●        Professional advisors

●        Authorities and others

●        Business transferees

None

Internet or Network Information

●        Device data

●        System data

●        Network data

●        Online activity data

●        Automatic collection

●        Service delivery

●        Research & development

●        Marketing

●        Compliance & Operations

●        Aggregated or anonymous data for analytics

●        Security, fraud protection, and safety

●        Business transfers

 

●        Affiliates

●        Professional advisors

●        Authorities and others

●        Business transferees

None

Inferences

●        May be derived from your:

●        Device data

●        Online activity data

●        Automatic collection

●        Service delivery

●        Research & development

●        Marketing

●        Compliance & Operations

●        Aggregated or anonymous data for analytics

●        Security, fraud protection, and safety

●        Business transfers

 

●        Affiliates

●        Professional advisors

●        Authorities and others

●        Business transferees

None

Professional or Employment Information

●        Job title

●        You

●        Service delivery

●        Research & development

●        Marketing

●        Compliance & Operations

●        Aggregated or anonymous data for analytics

●        Security, fraud protection, and safety

●        Business transfers

 

●        Affiliates

●        Professional advisors

●        Authorities and others

●        Business transferees

None

Protected Classification Characteristics

We do not intentionally collect this information but it may be revealed in identity data or other information we collect

●        You

●        Public sources

●        Business partners

●        Service delivery

●        Research & development

●        Compliance & Operations

●        Aggregated or anonymous data for analytics

●        Security, fraud protection, and safety

●        Business transfers

 

●        Affiliates

●        Professional advisors

●        Authorities and others

●        Business transferees

None

Education Information

●        Contact data

●        Identity data

●        You

●        Service delivery

●        Research & development

●        Compliance & Operations

●        Aggregated or anonymous data for analytics

●        Security, fraud protection, and safety

●         Business transfers

●        Affiliates

●        Professional advisors

●        Authorities and others

●        Business transferees

None

YOUR RIGHTS

 

In certain circumstances, if you are a California resident, you have the following data protection rights:

  • Information.  You can request the following information about how we have collected and used your Personal Information during the past 12 months:
    • The categories of Personal Information that we have collected.
    • The categories of sources from which we collected Personal Information.
    • The business or commercial purpose for collecting and/or selling Personal Information.
    • The categories of third parties with whom we share Personal Information.
    • Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient.
    • Whether we have sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.
  •  You can request a copy of the Personal Information that we have collected about you during the past 12 months.
  • Deletion.  You can ask us to delete the Personal Information that we have collected from you.
  • Opt-out of sales.  We do not currently sell your Personal Information.  If we plan to sell your Personal Information, you will be notified and you can opt-out.   In addition, if you direct us not to sell your Personal Information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.
  • Opt-in. We do not currently sell your Personal Information.  If we know that you are younger than 16 years old, we will ask for your permission (or if you are younger than 13 years old, your parent’s or guardian’s permission) to sell your Personal Information before we do so.
  • You are entitled to exercise the rights described above free from discrimination in the form of legally prohibited increases in the price or decreases in the quality of our Services.

HOW TO EXERCISE YOUR RIGHTS

You may exercise your California privacy rights described above as follows:

  • Right to information, access and deletion. You can request to exercise your information, access and deletion rights by:

 

 

 

  • Right to opt-out of the “sale” of your Personal Information. We currently do not sell your Personal Information.  If we plan to sell your information, you will be notified and you can request to opt-out of this “sale” of your Personal Information via a link we will provide at such time.

We reserve the right to confirm your California residence to process your requests and will need to confirm your identity to process your requests to exercise your information, access or deletion rights.  As part of this process, government identification may be required.  Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification.  We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.