Privacy Policy
Last Updated: September 26, 2024
Clover Learning Inc. (the “Company”, “we”, or “us”) recognizes the importance of data privacy, and this Privacy Policy sets forth the terms and conditions with respect to how we process your personal information. This Privacy Policy describes, among other issues, the types of personal information that we collect, the purposes for which we use it, the types of third parties with whom we share it, and any rights and responsibilities you may have with respect to such personal information.
This Privacy Policy applies to the personal information you provide us when you (i) visit any website that we own, license, or otherwise operate and that links to this Privacy Policy (each, a “Site”), (ii) purchase or receive products or services through the Site, or (iii) otherwise contact or engage with us. For purposes of this Privacy Policy, the Site and all information, products and services sold or furnished by Company through a Site shall be referred to collectively as the “Services.”
PLEASE READ THIS PRIVACY POLICY CAREFULLY AS IT DESCRIBES YOUR RIGHTS, RESPONSIBILITIES, AND LIABILITIES. BY ACCESSING OR USING THE SERVICES OR OTHERWISE PROVIDING US WITH PERSONAL INFORMATION, YOU ARE CONSENTING TO THE TERMS OF THIS PRIVACY POLICY, OUR TERMS OF USE AND OUR COOKIE POLICY.
Company is headquartered in the United States. For more information on our data transfer practices, please see Section 9 (Data Retention and Localization).
Scope
This Privacy Policy applies to personal information that Company receives during its business operations as a “data controller” - which means we determine the purpose and means of processing such personal information. For purposes of this Privacy Policy, the term “personal information” means any information that, alone or in conjunction with other information or data, identifies or is linked to a particular individual or household and that is subject to, or otherwise afforded protection under, a data protection law, statute, or regulation. The term “personal information” does not include anonymized or de-identified data that is not attributable to a particular individual or household and that is not otherwise subject to a data protection law, statute, or regulation. Company may anonymize or de-identify personal information, and such data is not subject to this Privacy Policy, and Company may use such data for any purpose.
The Types and Categories of Personal Information We Collect
Company collects personal information in order to provide our Services, comply with our legal obligations, promote our business interests, and for the other reasons set forth in this Privacy Policy. When you do not provide personal information to Company, we may not be able to provide you the Services or to complete a transaction you requested. Generally, we collect the following types and categories of personal information during our business operations:
Personal Information
Category
Description/Examples
Personal Identifiers
Identifiers, such as your name, alias, shipping address, email address, account name, telephone number, customer identification number.
Registration Data
Information provided when you register for an account to use the Site, including usernames and passwords.
Demographic Data
Data about you such as your country of residence and preferred language.
Payment Data
Data necessary to confirm that your payment has been processed by our third-party payment processor.
Online Identifiers (For more information, see “Collection of Technical/Online Data” below)
Persistent identifiers that can be used to recognize you or your device over time and across different services, including a device identifier, an Internet Protocol (IP) address, cookies, beacons, pixel tags, mobile ad identifiers, and similar technology.
Commercial Information
Records of the Services you purchased, obtained, or considered, or your other purchasing or consuming histories or tendencies with respect to our Services.
Business Contact Data
Information related to employees, owners, directors, officers, or contractors of a third-party organization (e.g., business, company, partnership, sole proprietorship, nonprofit, or government agency) with whom we conduct, or possibly conduct, business activities.
Marketing and Communications Data
Information with respect to your marketing preferences and your subscriptions to our publications and alerts.
Internet and Electronic Network Data
Data pertaining to your access or use of the Site, including browsing history, search history, and information regarding your interaction with the Site or advertisements embedded on the Site or other third-party websites, and information derived from any device that connects to our WiFi services.
Your Feedback
Information you provide about our Services, which may include data gathered from any Company surveys or reviews submitted by you.
Visitor Information
Information an individual provides when visiting any physical location or premises of Company (e.g., visitor logs and registries, vehicle and parking information).
Video and Images
In some circumstances, you may provide us images (e.g., your use of a product) or we may record you via a video camera (e.g., on-premises security systems) or through video teleconferencing.
Geolocation Data
We may collect data about your location, which may be either precise or imprecise. Precise location data can be obtained through Global Navigation Satellite System data, as well as through nearby cell towers and Wi-Fi hotspots when you enable location-based products or features. Imprecise location data includes, for example, a location derived from your device or data that indicates where you are located with less precision, such as an internet protocol (IP) address or a city or postal code.
Professional or Employment Data (For more information, see “Employment Applications and Talent Management” below)
If you apply for a job with Company, we collect information set forth in a resumé, curriculum vitae, cover letter, and similar documentation, including contact details, employment history, skills, or qualifications, education-level, job compensation and benefit preferences, criminal record, credit history and similar data, and information provided about or by your references.
Inferences
Inferences drawn from some of the personal information categories identified herein and used to create a consumer profile reflecting your purchasing and marketing preferences, characteristics, and behavior.
Collection of Technical/Online Data
In addition, when you access the Site, we collect certain data automatically using technical means and tools. This data relates to your device, as well as your experience on the Site and other websites, including the following:
Usage and Device Data. When you access and use the Site, we automatically collect details of your access to and use of the Site, including traffic data, usage logs and other communication data, and the resources that you access and use on or through the Site (e.g., browsing history, search history). We may also collect information about your device and internet connection, including the device’s unique identifier (e.g., device type, IMEI, Wi-Fi MAC, IP address), operating system, browser type, and mobile network information. The Site may collect “diagnostic” data related to your use of the Site, such as crash data and logs, performance data (e.g., launch time, hang rate, or energy use), and any other data collected for the purposes of measuring technical diagnostics.
Cookies and Tracking Data; Social Media. We use “cookies” and other tracking technologies within the Site. A cookie is a small file placed on your smartphone or other device. It may be possible to refuse to accept cookies by activating the appropriate setting on your smartphone or device. However, if you select this setting, some parts of the Site may become inaccessible or not function properly. In addition, the Site may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us to analyze data on your use of the Site (e.g., recording the popularity of certain content and verifying system and server integrity). The Site may collect data about the advertisements you have seen or engaged. For more information, see, where available, the Cookie Policy on each Site. From time to time, we may use on our Site certain third-party cookies and pixels provided by our marketing partners, including social media companies. To the extent we use such third-party cookies and pixels, you hereby agree to the terms and conditions set forth by those third parties, which may include Meta, X (formerly Twitter), TikTok, and LinkedIn, among others.
Site Monitoring. Please be aware that we, and our service providers and partners, use cookies and other tracking technologies within the Site to monitor and record any and all activities and communications to, from, and on, the Site. For the avoidance of doubt, you hereby acknowledge, agree, and consent to, such monitoring and recording by us and our service providers and partners.
Non-Cookie Technologies. We may deploy on our Site certain types of “Non-Cookie Technologies” provided by our service providers to support our digital advertising programs. These technologies often include browser cache, locally stored objects, or the creation of a statistical identifier wherein an identifier, much like a cookie identifier, is calculated based on the characteristics of a browser or device that distinguishes it from other browsers or devices. These identifiers are calculated either from the data your browser or device shares automatically or with additional data specifically requested from your browser or device.
Sources of Information
We collect personal information from the following sources:
First Party / Direct Collection. We collect personal information directly from you when you use our Services (e.g., registering accounts, completing purchases, signing up for subscriptions), when you provide a Product Review (as defined below), or whenever you directly engage with us, such as when you visit our offices or premises or otherwise contact us.
Automated Collection. As described above, we may collect information and data, such as usage data and cookies, through automated means when you use the Site (see “Technical Data” above).
Third-Party Sources. We also obtain data from third-parties. These third-party sources vary over time, but they are sources deemed credible by us and may be publicly available or available on a commercial basis. They can include: data brokers from which we purchase demographic data to supplement the data we collect; partners with whom we offer branded products or engage in joint marketing activities; fraud prevention agencies or credit reporting agencies in connection with credit determinations, if applicable; publicly available sources such as open government databases or other data in the public domain; social networking providers; advertising companies; and, third-party references. If you purchase our products from our distributors and business partners we may receive certain information about your purchase from them.
How We Use your Information / Purpose of Collection
We may use the personal information we collect about you in order to perform our Services, comply with our legal obligations, and promote our business interests. Please see below for more information on how we use personal information:
How We Use Personal Information
Provide, operate, maintain, improve, and promote our Services.
Enable you to access and use our Services.
Process and complete transactions, and send you related information, including purchase confirmations and invoices.
Send you messages and communications related to our Services (e.g., responses to your comments, questions, and requests, customer services).
Furnish technical notices, updates, security alerts, and support and administrative messages to you about our Services.
Provide you promotional and marketing communications (e.g., information about our Services, features, surveys, newsletters, offers, promotions, contests, and events).
Process and deliver contest or sweepstakes entries and rewards.
Monitor and analyze trends, usage, and activities in connection with our Services to promote our business interests.
Investigate and prevent fraudulent transactions, unauthorized access to or use of our Services, and other illegal activities.
Personalize our Services, including providing features or advertisements that match your interests and preferences.
Company may collect and use your personal information for any other purpose for which we obtain your consent.
For the avoidance of doubt, you hereby agree that Company may contact you via any means, including via SMS/text message and email (including through the use of autodialing systems and services), to furnish you information regarding a product order, shipping status, warranty-related information, and similar data and information pertaining to a commercial transaction.
Sharing Information / Third-Party Disclosures
We may share your personal information with certain organizations and third parties in accordance with applicable law, including as set out below. However, we do not share personal information with third parties that we have reason to believe use such information for their own direct marketing purposes.
Intra-Group Transfers. We share personal information, to our parent organization, and to and among Company affiliates and subsidiaries, to efficiently manage the operation of our business.
Service Providers. We may share your personal information with companies that provide services on our behalf, such as hosting and analyzing the Site, conducting surveys and marketing on our behalf, processing transactions, tracking and responding to consumer questions or complaints, and performing analyses to improve the quality of our Services.
Payment Card Transactions. All payments for purchases made through the Site are completed using a third-party vendor’s online payment system. Company does not have access to your credit card information and does not store or disclose your full credit card information. Any personal or financial information you provide to our online payment system is subject to the third party’s privacy policy and terms of use, and we recommend you review these policies before providing any personal or financial information.
Distributors and Business Partners. We may share your personal information with third parties that distribute our goods, products, and marketing materials.
Business Restructuring. Circumstances may arise where, for strategic or other business reasons, Company decides to sell, buy, divest, merge or otherwise reorganize our businesses. We may disclose your personal information to the extent reasonably necessary to proceed with the negotiation or with the completion of a merger, acquisition, divestiture or sale of all or a portion of Company’s assets.
Legal; Compliance; Legitimate Interests. We may disclose personal information (i) if required by law or government order, or with a legal process, (ii) to protect and defend our rights or property, or (iii) in urgent circumstances, to protect the health and personal safety of any individual. In addition, Company may disclose your personal information with any third party when we believe such disclosure is necessary to defend or protect our legal, regulatory, or business interests. We may also disclose your information upon your express consent.
Consent. In addition to the reasons for disclosure set forth herein, we may also disclose your personal information upon your consent.
In the event that you facilitate a transaction with Company, or request information from or otherwise engage with us, and such activities require Company to share your personal information with a service provider or other third party, you hereby consent to such disclosure and/or direct Company to intentionally disclose your personal information to the service provider or third party.
Social Media/ Platform Data Rights
We may engage with you on various social media platforms (e.g., Facebook, Twitter, Pinterest, Instagram). If you contact us on a social media platform for customer support or for other reasons, we may contact you via the social media’s direct message tools. Those communications to and from us are governed by this Privacy Policy. However, your use of a social media platform is also subject to the policies and terms of the relevant social media platform. Certain social media platforms may also automatically provide us with your personal information, the information we receive will depend on the terms that govern your use of the social media platform(s) and any privacy settings you may have set. The Site includes social media features and widgets (e.g., the “Facebook Like” button, the “Share This” button) or interactive mini- programs that run on the Site. These features may collect your IP address and which Site page you are accessing and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Site. Your interactions with these features are governed by the privacy statement of the relevant social media platform that provides them.
According to the terms and conditions governing certain social media platforms, you may request that the information, data, or other content we obtain from or through the social media platform (“Platform Data”) be deleted or modified. If you would like Platform Data related to you deleted or modified, please contact us in accordance with the “Contact Us” section below and (i) identify the social media platform at issue and (ii) the Platform Data that you would like deleted and/or modified, and if modified, the modification to said Platform Data. We may also delete Platform Data if requested by the social media platform.
Links to Other Websites; Your Direct Third-Party Disclosures
As a resource to you, the Site may include links to third-party websites or provide you the opportunity to disclose information directly to third parties (e.g., credit card processors). Our Privacy Policy does not
apply to such third-party websites or organizations. You assume all privacy, security, and other risks associated with providing any data, including personal information, to third parties via the Services. For a description of the privacy protections associated with providing information to third parties, you should refer to the privacy statements, if any, provided by those third parties.
Data Retention and Localization
The period during which we retain your personal information varies depending on the purpose for the data processing. For example, we retain personal information for as long as needed to provide you with our Services, to facilitate transactions you have requested, to comply with our legal obligations (e.g., tax filings, export control laws), to engage in marketing activities, and for as long as is necessary to defend our legal or business interests. In all other cases, we retain your personal information for as long as is needed to fulfill the purposes outlined in this Privacy Policy.
Company is based in the United States, and the personal information that we collect and process is retained and stored in the United States. Company uses service providers that store personal information on our behalf in the United States and in other countries where you may not be a resident. Please be aware that the United States, and these other countries, may not provide the same level of protection of personal information as in your country, state, or other jurisdiction of residence or nationality, and when transferred to the United States or elsewhere, your personal information may be accessible by, or otherwise made available to, local government authorities and officials pursuant to judicial and/or administrative orders, decrees, and demands, and/or other domestic laws, statutes, and regulations. Company does not participate in the U.S. Data Protection Framework. By continuing to provide us such information, you hereby acknowledge and agree that your personal information will be transferred to, and stored in, the United States and in the countries where our service providers are located.
Security
We seek to protect the security of your personal information and use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. HOWEVER, NO INFORMATION SYSTEM CAN BE FULLY SECURE, AND WE CANNOT GUARANTEE THE ABSOLUTE SECURITY OF YOUR PERSONAL INFORMATION. MOREOVER, WE ARE NOT RESPONSIBLE FOR THE SECURITY OF PERSONAL INFORMATION YOU TRANSMIT TO THE SITE AND/OR THE SERVICES OVER NETWORKS THAT WE DO NOT CONTROL, INCLUDING THE INTERNET AND WIRELESS NETWORKS, AND YOU PROVIDE US WITH ANY PERSONAL INFORMATION AND DATA AT YOUR OWN RISK. TO THE EXTENT PERMITTED BY LAW, WE SHALL NOT BE LIABLE OR OTHERWISE RESPONSIBLE FOR ANY DATA INCIDENT OR EVENT THAT MAY COMPROMISE THE CONFIDENTIALITY, INTEGRITY, OR SECURITY OF YOUR PERSONAL INFORMATION CAUSED BY A THIRD PARTY. The safety and security
of your personal information also depends on you. Where we have given you (or where you have chosen) a username and password to access our Services, you are responsible for maintaining the security and confidentiality of those credentials and not revealing them to others. You must contact us immediately (and in any event within twenty-four (24) hours) if you have reason to believe that your username or password to our Services has been compromised. You acknowledge and agree that we may contact you via email or other electronic communications in the event we are legally required to notify you of a data security incident or event related to your personal information.
No Data Collected from Children
The Site is not directed at, nor intended for use by, children. As a result, if you are under the age of sixteen (16), you are prohibited from accessing or using the Services (including the Site) or with providing us with your personal information.
Publicly Posted Information; Product Reviews
You may, from time to time, have the ability to submit via the Site a comment on, provide an opinion about, rate, or otherwise discuss our Services (a “Product Review”). In other circumstances, you may directly provide us feedback on our business, our business sector, or the Services (“Feedback”). Any information or content you post in a Product Review or in your Feedback may be available to other users of the Site (and our social media platforms) and may be retrievable by third-party search engines, and third parties may also be able to download or share your Product Review and Feedback to social media websites or elsewhere. We recommend that you guard your privacy and anonymity and not upload any information in your Product Review and Feedback that you wish to remain confidential. Any third party with access to your information via the Site will be permitted to use the information in the same manner as if you submitted the information directly to that third party. Publicly posting any information on the Site is entirely voluntary on your part, and we recommend you carefully consider the information you choose to make publicly available. As between you and Company, any and all Product Reviews and Feedback shall be considered our confidential and proprietary information. In order for Company to utilize such Product Reviews and Feedback, you grant to Company a non-exclusive, perpetual, irrevocable, worldwide, royalty-free license, with the right to sublicense, under all relevant intellectual property rights, to use, publish, and disclose such Product Reviews and Feedback in any manner we choose and to display, perform, copy, make, have made, use, sell, and otherwise dispose of Company’s and our sub- licensees’ products or services embodying such Product Reviews and Feedback in any manner and via any media we choose, without reference to the source. Company shall be entitled to use Product Reviews and Feedback for any purpose without restriction or remuneration of any kind with respect to you and/or your representatives.
Your Responsibilities
You are permitted, and hereby agree, to only provide personal information to Company if such personal information is accurate, reliable, and relevant to our relationship and only to the extent such disclosure will not violate any applicable data protection law, statute, or regulation or infringe upon a person’s data privacy rights or privileges. IF YOU PROVIDE PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO COMPANY, YOU EXPRESSLY REPRESENT AND WARRANT TO COMPANY THAT YOU HAVE THE FULL RIGHT AND AUTHORITY TO PROVIDE COMPANY WITH SUCH PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) AND THAT COMPANY’S USE AND PROCESSING OF SUCH PERSONAL INFORMATION AS SET FORTH HEREIN WILL NOT VIOLATE ANY PERSON’S RIGHTS OR PRIVILEGES, INCLUDING RIGHTS TO PRIVACY. YOU HEREBY AGREE TO FULLY AND COMPLETELY INDEMNIFY COMPANY FOR ANY CLAIMS, HARM, OR DAMAGES THAT MAY ARISE FROM YOUR PROVISION OF PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO COMPANY. YOU ARE PROHIBITED FROM PROVIDING US WITH “CONSUMER HEALTH DATA” OR SIMILAR HEALTH INFORMATION.
Updating Your Information
It is important that the personal information that you provide to us is accurate and reliable. In certain circumstances, you may have the ability to directly edit your account to update and change your personal information (e.g., name, telephone number, email, shipping address), and you must do so when
such changes are warranted. If our Site does not provide these capabilities, then you must write to us in accordance with the Contact Us section below so we can update our records.
U.S. State Privacy Rights
Data Privacy Rights. Pursuant to certain U.S. state privacy laws, you may have the following privacy rights with respect to your personal information:
To confirm whether or not we are processing your personal information and access such personal information.
To correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of your personal information.
To delete personal information provided by, or obtained about, you.
To obtain a copy of your personal information processed by us, in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
Submit a Privacy Request. To submit these abovementioned privacy requests, please contact us in accordance with the “Contact Us” section below. Where permitted by U.S. state law, you may designate an authorized agent to submit a privacy request on your behalf.
Privacy Request Verification Process. If you make any request related to your personal information, the Company will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. In particular, before granting you access to, erasing, or correcting, specific pieces or categories of personal information or otherwise responding to your request, the Company will, to the extent required or permitted by law, (i) require you (or your authorized agent) to verify your request via email, (ii) request certain contact information or government identifiers, and (iii) match at least two pieces of such personal information with data that we have previously collected from you. None of your privacy rights are absolute, and such rights are subject to exceptions and exemptions.
Privacy Requests Appeals Process. If you would like to appeal a decision the Company has made with respect to your privacy request, please email us in accordance with the “Contact Us” section listed below, with the subject line “ATTN: Privacy Appeals,” and describe the nature of your request, and the reason for requesting an appellate review.
Marketing Preferences
You may, at any time, opt-out from receiving marketing emails from us. To opt-out from such marketing, please use the “unsubscribe” features within our email communications, or contact us in accordance with the “Contact Us” section below.
Do-Not-Track Signals
Some web browsers may transmit “do-not-track” signals to the website with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is
not always clear whether users intend for these signals to be transmitted, or whether they are even aware of them. Unless otherwise required by law, we currently do not take action in response to these signals.
Persons with Disabilities
Company strives to ensure that every person has access to information related to our Services, including this Privacy Policy. Please contact us if you would like this Privacy Policy provided in an alternative format, and we will seek to meet your needs.
Employment Applications and Talent Management
As part of our recruitment and talent management process, we collect personal information with respect to individuals who are interested in working for us. In this context, we collect employment and application data, such as the following: contact information (e.g., name, title, residential or postal address, telephone number, and personal email address); information in a curriculum vitae, resumé, cover letter, or similar documentation; details regarding the type of employment sought, willingness to relocate, job compensation and benefit preferences; health data (e.g., medical conditions); information related to your background, education, criminal record, credit history and similar data; information provided about or by your references or other third parties related to your employment history, skills, qualifications, or education; and information related to previous applications to us or previous employment history with us. When permitted by law, we may collect information about your race and ethnicity to assist with our diversity and inclusion programs.
We use this information for the following purposes: to identify and evaluate job applicants; to verify your information; to complete employment, education, background and reference checks; to communicate with you about the recruitment process and your application; to comply with our legal, judicial, regulatory, administrative, or other corporate requirements; to analyze and improve our application and recruitment process; to accommodate individuals who may have specialized needs during the employment process; and to protect the rights, interests, and property of our business, other job applicants, employees, or the public, as required, or permitted, by law.
We share this personal information with third parties (see “Sharing Information / Third-Party Disclosures”), and we may also use this employment and application data for any other purpose set forth in this Privacy Policy.
Please see above for any privacy rights you may have with respect to this personal information.
Events and Video Teleconferencing
Company hosts and uses video teleconferencing platforms to facilitate conferences, meetings, training events, and other programs. We often use online platforms that are owned and administered by a third- party service provider (e.g., Google, Zoom, WebEx, Skype for Business). Please be aware that our video teleconferencing may record the content, conversations, and discussions thereon, and such records may be stored or retained by our third-party service providers. By participating in our events and video teleconferencing, you hereby consent to the collection and retention of any information provided therein, and you hereby consent to the recording of such activities.
Changes to the Policy
We reserve the right to amend this Privacy Policy at any time. We will notify you if this Privacy Policy is amended by updating the “Last Updated” section listed above. It is your responsibility to periodically review the Privacy Policy to determine whether any amendments have been made hereto. Your use of the Services, and continued use of the Services after any amendments are made to this Privacy Policy, signifies your consent to this Privacy Policy and any amendments hereto. We may, in our sole discretion, provide you communications, including via email or text messages, about changes to our Privacy Policy; however, such communications do not abrogate or otherwise limit your responsibility to periodically review the Privacy Policy to determine whether any amendments have been made hereto.
Contact Us
If you have questions regarding this Privacy Policy or our handling of your personal information, would like to request more information from us, or would like to exercise a data privacy right, please contact us at support@cloverlearning.com.