Privacy Policy

Effective Date of Last Update: July 9, 2018

INTRODUCTION

Ednology (“Ednology“, “we“, “us“) understands that data collected from individualsis important to our users and that it is incumbent upon us to be as transparent as possible about our privacy practices.

For the provided set of resources and materials to be adaptive and be personalised to each customer, we rely on information from users. We are providing this privacy policy (the “Privacy Policy“) to help you understand our commitment to your protection and be fully transparent about the collection, use, storage, and disclosure of information that we (i) collect from visitors to our e-commerce portal (the “Site“) and (ii) users of our services, learning contents, tools and the other features, functionalitieswe make available as part of the Site (collectively, the “Resource“) sold via Site.

Whether you are accessing our Site as a visitor or are using our Resource (individually “you“), we view your continued use of our Site and the set of provided Resources as acceptance of the practices outlined in this Privacy Policy. If after reviewing this Privacy Policy you still have questions about our privacy practices, you can reach our privacy team at info@ednology.com.

Under the purposes of the General Data Protection Regulation, EU 2016/679 (GDPR), Ednology business is designed as the Data Controller of this privacy policy.

FROM WHOM DO WE COLLECT INFORMATION?

Our Site and the Resource are intended for users at least 16 years of age. Accordingly, we limit access to the Resource to users that identify themselves as at least 16 years of age when establishing a Ednology Account and only provide access to certain activities, content, and collection of PII (“Personally identifiable information”) to such Registered Users. We collect information and Usage Data (as further detailed in the next section) directly from Site visitors and from our Resource when a Registered User creates a Ednology Account and also as that Registered User accesses and interacts with the Resource. We may also receive information (including PII) from your Institution (and in some cases from your Institution’s learning management system (LMS)) regarding set up, course content, and other information specific to the material we deliver to you. We may also receive confirmation of your Resource purchase from our payment processor.

For visitors to our Site without a Ednology Account, we may ask for your email address to subscribe to our newsletter(s) created exclusively for marketing and promoting purposes.

WHAT INFORMATION DO WE COLLECT?

The types of information we collect and receive when you use the Resource and visit our Site falls into four categories:

• Direct Identifiers and other information you provide directly to us such as first name, last name, and/or email address or other contact information (e.g. telephone number), educational institution-issued student identifiers or other government-issued identifiers, images identifiers (e.g. photo) for the purpose of setting up your account.
• Direct Identifiers, Indirect Identifiers and other information you provide directly to our payment processors when you purchase the Resource through ednology.com e-commerce portalsuch as billing address, purchase history and credit card or other payment method.
• Information we generate automatically in order to provide your services such as Indirect Identifiers for your Ednology Account and Usage data we collect automatically through your interactions with our Resource and which may be combined with Direct or Indirect Identifiers to support personalization of your course experience.
• Information gathered through our Site.

Information You Provide Directly to Us

If you register for our Site, we will ask for your name, email address and birthdate to create a Ednology Account and become a Registered User, enable and validate your use of our Site, communicate with you about your use of the Site, provide product support, and comply with regulations.

If you are a Registered User, we receive and store any PII you knowingly provide us. However, we only collect the minimum necessary Direct Identifiers from you that are relevant to providing our Resource. For example, to set up a Ednology Account we will typically only ask for your first and last name, and an email address.

You may also provide us PII when you submit content to the Site and in connection with your use of the social networking features available, such as email or feedback functionality within the Resource. For example, our feedback tools allows you to add comments and take a snapshot of your screen and submit it to us as feedback. You control what information you put in those comments or what is on your screen at the time you submit the feedback, which could include PII such as your name, email address, grade data, etc.

Information You Provide to Our Payment Processing Partners and other Third Party Providers

Ednology’s Sitemay utilise business partners for data storage and integrated applications to enhance our Site functionality. If you are a Registered User who purchases Resource directly through Ednology.com, you will be required to provide payment processing information to Paypal or other third party PCI-Compliant subscription and billing management services. Ednology authorises these parties to collect from you only the minimum necessary information required to manage your subscription or process your payment and to share only the minimum necessaryfor the sole purpose of completing your transaction.

The e-commerce portal may utilise other business partners for data storage and integrated applications to enhance our Site functionality. In most cases these other business partners will not collect PII with Direct Identifiers from you. Where these business partners are able to collect PII from you through the Site, we contractually require that such business partners protect the privacy and security of the PII collected and strictly limit their use of such PII to the purposes of storing or processing such data to facilitate the hosting and delivery to you of our Site. Wherever feasible, we will only use business partners that have privacy policies and practices as strong as our own.

The Site (including inherent purchasableResource) may also contains links to other web sites. We encourage our users to read the privacy statements of these external web sites.

Usage Data Collected Automatically

Registered Users of our Site benefit from Ednology’s adaptive learning technology which personalises content for each user. In order to accomplish this, we automatically collect Usage Data as users interact and access the Resource. This data may include, but is not limited to, descriptions of content and problems a user has viewed and attempted, problems a user has answered correctly or incorrectly, content a user has viewed, the amount of time spent viewing content, etc. We only collect Usage Data that we believe is necessary to provide personalised learning and analytics through our Resource.

Typically, data collected automatically, including Usage Data, is Non-Personal Data. Where we combine this Usage Data with a Registered User’s Direct or Indirect Identifier(s) through a Ednology Account, we will treat this identified Usage Data as PII.

Other Information Collected Automatically

We also collect additional Non-Personal Data from users of the Site that is not permanently associated with any online account or registration information, and that cannot be used to directly contact you or identify you. For example, Non-Personal browser metadata from visitors to our Site which is ordinarily in aggregate, summary, or other anonymous form, and may include, by way of example, statistics regarding popularity of particular pages within the Site, or information regarding types of Internet browsers used by Registered Users. We also collect Non-Personal Data about users’ IP address to help diagnose problems with our server, and to administer our Site and the Resource. Such Non-Personal Data is not associated with individual account profiles or registration information.

Third party data collection

The Site currently use third party resources and services such as third party plug-ins and pixels. Entering in the details, we currently use the following set of third party resources that may collect data:

• Mailchimp a marketing tool used to collect and manage our email marketing campaign. The user may consult its privacy policy here.
• Google Analytics a specific set of powerful tools directly provided by Google used by into the Site for collecting and managing the Metrics data as, but not limited to, the IP addresses, browser characteristics and navigation session logs of any user. You may consult its privacy policy here.
• Social media platforms and pixels we may use these resources for a wide range list of reasons as redirecting the user to our social media accounts or interacting with them. The user may consult these Privacy Policies here and here.
• Wix Platform that currently hosts the Site and allows its main functionalities. The user may consult its privacy policy here.

Online Tracking.

“Cookies” are small files placed on a user’s computer by a Web site in order to facilitate use of that Web site. For example, a cookie may contain information about a user’s preferences, so that the Web site automatically complies with your preferences whenever the user visits that Web site. For example, you may prefer to use Google to sign in or you may choose to use a specific browser. A cookie helps us remember these preferences. When you visit our Site, we may create “cookies” on your computer for the purpose of facilitating and maintaining your current user session and create a more user-friendly experience. From time to time our cookies may include limited persistent identifiers to enable us to identify you in connection with the Resource and to track your place in our Resource and for purposes consistent with this Privacy Policy.

HOW DO WE USE AND SHARE COLLECTED INFORMATION?

Necessary Uses and Disclosures

For users of our Site who have created a Ednology Account, we use and/or share PII as necessary to provide personalised learning material and products through the Site and as further described below. We also describe below how we use and share Non-Personal Data.

The types of disclosures described below (“Necessary Disclosures”), to the extent applicable to your use of the Resource, are necessary if you wish to use the Resource. As mentioned above, we may use Non-Personal Data for business purposes. If you do not want us to make such Necessary Disclosures, or do not want us to use Non-Personal Data without restriction, you must not use the Resource.

• We use PII as strictly necessary to provide personalised material through the Resource. For example, we will use certain Personal Identifiers to allow you to create a Ednology Account so that we can identify you in order to maintain a longitudinal learning profile across materials within the Resource.
• In limited circumstances we may disclose collected information or direct you through the Site to provide information, including PII, to certain of our business partners who provide certain functionality in connection with providing the Resource.
• We also use both PII and Non-Personal Data in a variety of ways when evaluating ways to improve the Resource. Some examples are to evaluate the performance of the Resource and the general preferences of users, or to generate aggregated and anonymised statistics. Because Non-Personal Data cannot be used by us to identify an individual, this Privacy Policy does not limit our ability to use or disclose Non-Personal Data.
• We use PII to make necessary communications regarding our Resource. For example, we may email you to provide an update to our Terms of Service or this Privacy Policy or a request for a password reset.
• Under certain circumstances, we may be subject to legal requirements to disclose information collected through the Site, such as, by way of example, to a court or a governmental agency, and our policy is to comply fully with all such legal requirements.
• We may also disclose information collected through the Site whenever we reasonably believe that disclosing such information is necessary or advisable to protect the rights, property, or our safety or the safety of others.
• Finally, we may disclose and use your personal information for marketing and promotional purposes.

Other Uses and Disclosures:

If you are a visitor to the Site and do not directly provide us information as described above, please note that we do not collect or store any Direct Identifiers but may retain visitor information for statistical analysis.

Also, as we develop our businesses, we might sell businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, PII and Non-Personal Data may be part of the transferred assets. Any sharing and other transfers of PII and Non-Personal Data contemplated by this paragraph are Necessary Disclosures for the purposes of this Privacy Policy.

YOUR RIGHTS UNDER THE GDPR

As between us and our users and subject to the terms of this Privacy Policy, our users have control over what PII we collect, how we use and share it, and the ability to delete (or, if applicable, permanently de-identify) that PII at all times.

You may update the Direct Identifiers in your Ednology Account at any time by logging into your account and accessing the PII in your account settings. Additionally, if you are a Registered User who has purchased the Resource directly through Ednology.com, you can access your payment processing information (including updating your Direct Identifiers, credit card information and billing address) through the “Billing Information” section of the Site.

You can delete your Ednology Account by going to the account page and clicking “Delete Account.” When you select to delete your Ednology Account, Ednology will delete or de-identify your PII that we have collected or received during your use of the Resource. Additionally, if you have entered payment information, when you delete your Ednology Account, Ednology will permanently remove from our systems any link between your Ednology Account and your payment processing information.

Although it is technically unfeasible to display all the Usage Data linked to your Ednology Account, you can access your learning history (e.g. problems you have viewed and attempted, problems you have answered correctly or incorrectly, etc.) from assignments you have worked on within the Resource by clicking on any assignment.

Additionally, you have the chance to request a removal action inherently toany PII and non personal information that you directly or indirectly provided to us.

If you want to understand exactly what types of information are stored within your Ednology Account, update your PII, understand who you have authorised to access your Usage Data, or if you discover any difficulties with our deletion process, please contact us at our official email address.

Finally, you may refuse to allow us the use of your sensitive data for marketing and promotional purposes at any time, as permitted by the GDPR regulations. You can exercise this right simply sending us a communication that directly expresses your intention.

HOW DO WE SECURE AND PROTECT COLLECTED INFORMATION?

The security of your PII is of utmost importance to us. We have put in place what we view as necessary physical, managerial, and technical safeguards to protect PII from loss, misuse, and unauthorised access, disclosure, alteration, or destruction.

IMPORTANT NOTICES TO NON-UK AND NON-EEA (“EUROPEAN ECONOMIC AREA”) RESIDENTS

We primary operate from UK. Laws of the European Union or other regions of the world govern data collection and use that differ from U.S. law and may prohibit the transfer of Direct Identifiers and Indirect Identifiers to the United States unless certain requirements are met. If you are a non-UK/EEA residents and notwithstanding this notice you still chose to create a Ednology Account and use and access the Resource, you acknowledge and agree that you are doing so under free will and consent, to the maximum extent permitted under applicable laws, to the collection and transfer of your PII outside of those regions to the UK/EEA and to our use of such information in accordance with this Privacy Policy and our terms of service.

CHANGES TO THIS POLICY

If we change this Privacy Policy, we will post those changes on the Site so that all users of the Resource are aware of what information we collect, how we use it, and under what circumstances, if any, we will disclose it. Any such posted changes will be effective upon the date indicated by the posting, but in any event not sooner than 14 days after posting.

CONTACTING US

If you have questions about this Privacy Policy, questions about the quality, safeguards, use, disclosure, or housing of your PII, or if you have suggestions or feedback, please contact us via:

E-mail: info@ednology.com