Please read this Privacy Policy
carefully.
Simply
Smart Learning, LLC (“Company”, “we”, “us”,
and “our”), is committed to ensuring the security and protection
of the personal information that we collect. This Privacy Policy includes (a)
our products or services and processes, which may result in the collection of
personal data; (b) the purpose for processing personal data; (c) the persons or
entities with whom we share personal data; and (d) how long we maintain
personal data. This Privacy Policy applies to:
·
All information we collect through the products,
events, promotions, surveys, contests and all other services (collectively, the
“Services”) provided on our website, along with all applications
and platforms, including mobile websites, applications and platforms, any
affiliated or non-affiliated third party sites, and all social media platforms
(collectively, the “Sites”); and
·
All current, potential and former
employees, users, independent contractors, vendors, third parties and/or any
other person whose personal data we have collected electronically, in person or
otherwise.
Special Note:
The Sites are general audience sites and are not designed or intended to target
children younger than 18. We do not knowingly target or collect personal
information from any person younger than 18.
What Information Do We Collect?
Information
We Collect Automatically. If
you use the Sites, read or download information, your web or mobile browser may
automatically send us your internet or other network activity including one or
more of the following (collectively,
“Network Information”):
·
Your
internet protocol (IP) address, registration date, and one or more cookies that
may uniquely identify your browser;
·
Your
internet domain and the specific path, actions and navigation choices;
·
The
internet address of the site from which you linked the Sites, and the time and
date you accessed the Sites;
·
Your
browsing history, search history, information on your interaction with the
Sites or other websites and applications or advertisements; and
·
Your
browser software, operating system and browser language, and information about
your location and mobile device, including a unique identifier for the mobile
device.][1]
Why We
Collect: We collect this information for business and commercial
purposes, including in order to:
ü
Maintain or analyze the functioning of
the Sites or Services and to maintain network communications;
ü
Monitor
and analyze web traffic and online behavior for search engine optimization and
social media marketing;
ü
Host
data files that enable the Sites to function, be distributed, and to provide
specific features or parts of the Sites;
ü
To
create, maintain, customize, secure, and manage your accounts with us,
including for accounting, finance, and dispute resolution purposes (such as
accounts receivable, accounts payable, account reconciliation, cash management,
or money movement) and for consolidated management and reporting;
ü
To
personalize your experience on the Sites and to deliver content and Services
relevant to your interests and requests through our Sites (with your consent as
required by law);
ü
To
process your requests, purchases, transactions, and payments and to prevent
financial fraud and other illicit activity;
ü
For
testing, research analysis, and product development, including to develop and
improve the Sites and Services;
ü
Initiate,
assess, develop, maintain, or expand a business relationship, including
negotiating, contracting, and fulfilling obligations under contracts;
ü
Manage
a database of email information, phone information or other information and
send transactional communications (such as requests for information, responses
to requests for information, orders, confirmations, training, and service
updates);
ü
Assure
quality control and to enforce Company’s standards and policies;
ü
Manage
security, including monitoring individuals with access to the Sites and
Services, applications, systems, or facilities, investigation of threats, and
as needed for any data security breach notification;
ü
Manage
relationships with current and potential customers and for marketing purposes,
including sending marketing, promotional, product and service, and customer
communications and surveys and other communications to individuals who have not
objected to receiving such communications;
ü
Anonymize
or de-identify the personal information;
ü
View
and incorporate content hosted on external sites;
ü
Respond
to law enforcement requests and as required by applicable law, court order, or
governmental regulations; and
ü
Process payment information and
transactions.
Information
You Give To Us and Information We Collect From Others. If you use the Sites or Services, or
you otherwise use or purchase our Services, we receive and store information
you enter on the Sites, or that you give us in-person, via telephone, email, or
otherwise. We may also collect personal
information from third parties that operate (a) portions of the Sites and
Services on our behalf or (b) independent websites. When we obtain personal
data from third parties, we will treat the acquired information like the
information that we collect ourselves. Depending on the Services we provide to customers
and/or the services being provided to us by other third parties, we may collect
(and over the previous 12 months have collected) the following information
about you from you and/or others:
·
Network
Information;
·
Personal
information and identifiers, such as name, postal address, email address, telephone
numbers, account name, social security number, driver’s license or state identification
card number, passport number or other similar information, physical
characteristics or description, education, employment, employment history, bank
account number, credit card number, debit card number, or any other financial
information (collectively, “Personal Information and Identifiers”);
·
Protected
classification information, such as race, color, ancestry, national origin,
citizenship, religion or creed, marital status, medical condition, physical or
mental disability, sex (including gender, gender identity, gender expression,
pregnancy or childbirth and related medical conditions), veteran or military
status, sexual orientation or other similar information (collectively, “Protected
Class Information”);
·
Commercial
information, such as the Services purchased, obtained or considered, or other
purchasing or consuming histories (collectively, “Commercial Information”);
·
Biometric
and identifying information, such as fingerprints, faceprints, voiceprints,
iris or retina scans, keystroke, gait or other physical patterns, and sleep,
health or exercise data, genetic, physiological, behavioral and biological
information or other similar information (collectively, “Biometric
Information”);
·
Sensory
data, such as audio, electronic, visual, thermal, olfactory or similar
information (collectively, “Sensory Information”);
·
Geolocation
data, such as physical location or movements (collectively, “Geolocation
Information”);
·
Professional
or employment-related information, such as work history and job descriptions
with current and prior employers (collectively, “Employment Information”);
·
Education
information, such as student financial information, grades, transcripts, class
lists and other records related to a student maintained by an educational
institution or party acting on its behalf (collectively, “Education
Information”); and
·
Inferences
drawn from any of the personal information listed above to create a profile or
summary, such as, for example, an individual’s preferences, abilities,
aptitudes, predispositions, and characteristics (collectively “Profile
Information”).
We collect this information for
business and commercial purposes, including in order to:
ü
To
create, maintain, customize, secure, and manage your account with us, including
for accounting, finance, and dispute resolution purposes (such as accounts
receivable, accounts payable, account reconciliation, cash management, or money
movement) and for consolidated management and reporting;
ü
To
personalize your experience on the Sites and to deliver content and Services
relevant to your interests and requests through our Sites (with your consent as
required by law);
ü
To
process your requests, purchases, transactions, and payments and to prevent
financial fraud and other illicit activity;
ü
For
testing, research analysis, and product development, including to develop and
improve the Sites and Services;
ü
Initiate,
assess, develop, maintain, or expand a business relationship, including
negotiating, contracting, and fulfilling obligations under contracts;
ü
Perform
due diligence regarding an individual’s qualifications and eligibility for the Services,
including verifying the identity, qualification, authority, and
creditworthiness of the individual and obtaining publicly-available information
from third parties (such as publicly-available sanction lists from screening
companies);
ü
Manage
a database of email information, phone information or other information and send
transactional communications (such as requests for information, responses to
requests for information, orders, confirmations, training, and service
updates);
ü
Assure
quality control and to enforce Company’s standards and policies;
ü
Manage
and mitigate risk, including for audit and insurance functions, and as needed
to meet our obligations and to protect assets;
ü
Manage
security, including monitoring individuals with access to the Sites,
applications, systems, or facilities, investigation of threats, and as needed
for any data security breach notification;
ü
Monitor
and analyze web traffic and online behavior for search engine optimization and
social media marketing;
ü
Host
data files that enable the Sites and Services to function, be distributed, and
to provide specific features or parts of the Sites and/or Services;
ü
Manage
relationships with current and potential customers and for marketing purposes,
including sending marketing, promotional, product and service, and customer
communications and surveys and other communications to individuals who have not
objected to receiving such communications;
ü
Anonymize
or de-identify the personal information;
ü
View
and incorporate content hosted on external sites;
ü
Respond
to law enforcement requests and as required by applicable law, court order, or
governmental regulations; and
ü
Process payment information and
transactions.
How We Collect Information From
Customers. Pursuant to our
agreements with customers, and in order to perform and provide the Services
thereunder, our customers may provide us with information about their clients, employees
and contractors when using the Sites or Services.
How We Collect Information From Other
Third Parties. We
may use cookies to recognize you when you return to the Sites in order to
provide you with a better user experience. We also allow our affiliates and
third-party vendors to use cookies on our Sites; some of these parties may use
cookies in ways that we do not. You may refuse to accept cookies by activating the setting on
your browser which allows you to refuse the setting of cookies. However, if you
select this setting you may be unable to access certain parts of the Sites.
Unless you have adjusted your browser setting so that it will refuse cookies,
our system will issue cookies when you log onto our Sites.
Facebook,
Instagram, & Google. Technologies like cookies, pixel
tags, device or other identifiers and local storage are used to deliver,
secure, and understand products, services, and ads, on and off Facebook,
Instagram, Twitter, LinkedIn, YouTube, and related social media platforms. They
also are used to gather information for remarketing to similar audiences on our
Sites. Because of this, third-party vendors, including Google, show our ads on
sites across the internet. This technology allows third-party vendors,
including Google, to use cookies to serve ads based on someone’s past visits to
our Sites. You may opt out of Google’s use of cookies by visiting Google’s Ads
Settings. You may also opt out of a third-party vendor’s use of cookies by
visiting the Network
Advertising Initiative opt-out page.
Do We Share Information With Third
Parties?
We take reasonable precautions to be sure that nonaffiliated
third parties and affiliates, to whom we disclose your personally identifiable
information are aware of this Privacy Policy and will treat the information in
a similarly responsible manner. Our contracts and written agreements with
nonaffiliated third parties that receive information from us about you prohibit
those parties from transferring the information other than to provide the Services
that you obtain from us.
Over the previous 12 months, we have shared the following
categories of personal information with third parties: Personal Information and
Identifiers, Protected Classification Information, Commercial Information,
Biometric Information, Network Information, Sensory Information, Geolocation
Information, Employment Information, Education Information, and Profile Information.
We will not disclose your personal information to third
parties except to provide you with information or services you request, deliver
our Services that include your personal information, or under certain
circumstances as described in this Privacy Policy, including:
Your
Consent. We
may share personal data with your consent.
Disclosure
For Legal Reasons. We
may release personal data to third parties: (a) to comply with valid legal
requirements such as a law, regulation, search warrant, subpoena or court
order; or (b) in special cases, such as a physical threat to you or others, a
threat to homeland security, a threat to our system or network, or cases in
which we believe it is reasonably necessary to investigate or prevent harm,
fraud, abuse, or illegal conduct. We
may also disclose personal data where needed to affect the sale or transfer of
business assets, to enforce our rights, protect our property, or protect the
rights, property or safety of others, or as needed to support external
auditing, compliance and corporate governance functions.
Agents
& Contractors. Our
contractors sometimes have access to your personal data in the course of
assisting in the operation of our business and providing Services to you. These
contractors include vendors and suppliers that provide us with technology,
services, and/or content for the operation and maintenance of the Sites and the
Services. Access to your personal information by these contractors is limited
to the information reasonably necessary for the contractor to perform its
limited function. Contractors have an obligation under their contracts with us
to keep your information confidential and to comply with our privacy and
security policies.
Links
To Other Sites. The Sites may
contain links to other websites and resources located on servers maintained by
third parties. These links are provided for your convenience and information
only and, as such, you access them at your own risk. When you click on one of those links, we will
not provide any personal information about you, but may let the site know that
you came from the Sites. We do not control the privacy practices and policies
of other sites. Please read their privacy policies in order to understand what
information they collect about you and how they use it.
Aggregated,
Non-Personal Information. We
may share aggregated, non-personal information about you with third parties.
This is information that is combined with the non-personal information of other
users and does not allow you to be identified or contacted. Depending on the
circumstances, we may or may not charge third parties for this aggregated
information. We also may not limit the third parties’ use of the aggregated
information.
Changes
In Our Corporate Structure. If
all or part of the Company is merged, acquired or otherwise transferred to
another entity, the personal data you have provided to us may be transferred as
part of that transaction. We will take steps to ensure that any personal data
that is transferred will not be used or shared in a manner inconsistent with
this Privacy Policy, as it may be amended.
Do We Sell Your Personal Information?
No. Although the
Company shares data with third parties as outlined in this Privacy Policy, the
Company does not sell any of your personal information to any third party.
How
and Where Do We Process and Store Data?
The data processing is carried out in
accordance with our privacy procedures and policies and using computers and/or
related software and IT tools. In some cases, the data may be accessible to
certain types of (i) internal parties in charge or involved with the operation
of our Sites and Services (i.e., administration, legal, sales and marketing,
etc.) or (ii) external parties who assist us in providing, operating, and
maintaining our Sites and Services, (i.e., third-party technical service
providers, mail carriers, hosting providers, communications agencies, etc.).
Still, we notify both internal and external parties of this Privacy Policy and
require that internal parties (through employment agreements and related
employment policies) and external parties (through written agreements) keep and
maintain the data in accordance with the safeguards described in this Privacy Policy
and related policies and procedures.
How Do We Protect Personal Data?
The
Company protects data using administrative, technical, and physical
safeguards. When we use third-party
service providers, we ask those providers to implement similar safeguards.
However, we cannot guaranty that your information is completely secure either
within the Company or on the systems of third party service providers.
How Long Do We Keep Your Personal Data?
We
retain personal data we collect from you when we have an ongoing legitimate
business need to do so (i.e., to provide you with the Services you have
requested or to comply with applicable legal requirements). When we no longer
have an ongoing legitimate business need to process your personal information,
we will physically destroy, delete or anonymize it or, if this is not possible,
then we will securely store your personal data and isolate it from any further
processing until deletion is possible.
How
To Contact Us
If you have any questions regarding
this Privacy Policy or exercising any of your privacy rights, please contact us
at the email address listed below:[2]
Email Address: info@simplysmartlearning.com
Changes
To This Privacy Policy
We reserve the right to amend this
Privacy Policy at our discretion and at any time. When we make changes to this
Privacy Policy, we will give notice to you via (i) the Sites or (ii), where
feasible, and at our discretion, contact information available to us. We
encourage you to periodically review this Privacy Policy so as to remain
informed on how we are protecting your information.