and all of their respective subdomains and web sites.
Marketplace Simulations offers several learning applications (the “Learning Tools”) on the Sites. These Learning Tools include Marketplace® business simulation, and Marketplace Microsimulations® that are hosted on the Sites.
WHEN REGISTERING FOR USER ACCOUNT OR OTHERWISE USING THE SITE, YOU WILL BE REQUIRED TO CONFIRM THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO COMPLY WITH THIS POLICY. PLEASE READ THIS POLICY CAREFULLY AS IT DESCRIBES OUR PRIVACY POLICIES AND PRACTICES. IF YOU DO NOT AGREE WITH OUR PRIVACY POLICIES AND PRACTICES, DO NOT USE THE SITE.
THIS POLICY MAY CHANGE FROM TIME TO TIME WITH NOTICE TO YOU. BY CONTINUING TO USE THE SITE AFTER YOU ARE NOTIFIED OF ANY CHANGES, YOU ACCEPT THOSE CHANGES.
1. Who is Responsible for your Personal Information?
We are the party responsible for processing data on this Site. We observe certain legal and compliance measures with regard to the personally-identifiable information (any information that identifies or is identifiable to a natural person under U.S. and other laws that may apply) that you provide to us through our Site and associated services.
If you are a user in the European Union (the "EU"), the European Economic Area ("EEA"), or the United Kingdom (UK), for purposes of the EU General Data Protection Regulation, 2016/679 (the "EU GDPR") or the UK Data Protection Act of 2018 (the “UK GDPR”), or any successor legislation (collectively, "Data Protection Laws"), we may act as a data controller or processor for the "personal data" we collect from you via our Site. For those users in Canada, we may collect “personal information” from you in connection with certain commercial activities associated with the Learning Tool and we do so in compliance with the Privacy Act and the Personal Information Protection and Electronic Documents Act (PIPEDA).
Whenever we disclose your personal data to our organizational affiliates, or vice versa, we will inform you of our lawful basis for doing so and honor your rights with respect to the processing of your personal data. We also will let you know if an entity other than us is acting as a controller or processor of your data when you request a product or service from us.
2. Collection of personally-identifiable information
Marketplace Simulations collects, processes, stores, and transfers personally-identifiable information that you submit through the Site, and email, telephone, fax, or postal mail relating to your participation in the Learning Tools and our provision of the Site and its other services and Content, including:
- Your User Profile. You be asked by us or your instructor to provide or otherwise may choose to provide us with your first name, last name, username, school affiliation, postal address, email address, telephone number, billing information, gender, nationality, age, academic grade point average (GPA), photo, and other information about your interests and preferences you may wish to feature on your profile. Your profile information may also include your username and password, purchases or orders made by you or on your behalf, and your interests, preferences, and feedback. While some basic profile information will be required to maintain an active, functional user profile on the Site, your submission of the foregoing information is voluntary.
- Content You Share. You may choose to communicate with us, your instructor, your classmates, or other users via messaging, media upload (of photos, videos, etc.), and/or chat features of the Site or a third party messaging service. We collect the content you create and upload on our Site as well as information about that content, such as if the recipient has viewed the content and metadata associated with the content. If you share your information or content with other users, or any type, please remember that your messages, chats, and any other information or media submitted may be further shared by that user with others or become public. Please exercise caution before sharing any non-public information with other users of the Site and respect the Acceptable Use restrictions listed on our Site.
- Business Information. This includes information provided in the course of the contractual or client relationship between you or your organization and us, or otherwise voluntarily provided by you or your educational institution or organization.
- Usage Data. When you access and use the Site, we may automatically collect certain details of your access to and use of it, including traffic data, location data, logs, and other communication data. This includes how and with whom you communicate via the Site using chat and messaging, such as the names or usernames of users, the time and date of your communications, the number of messages and chats you exchange with other users, which users you exchange messages and chats with the most, and how you interact with chats and messages (such as when you open a message or chat).
- Device Data. We automatically collect certain information that your Internet-enabled device sends when you use our Site, including your IP address, some user settings, which may include device model, connection and browser type, and operating system in use. Depending on your device type and device and browser settings, this information may provide geographic, time zone, or other location information associated with your device.
- Marketing and Communications Preferences. These include your preferences in receiving marketing from us and third parties and your communication preferences. We offer you control over the various types of optional communications made available by us to you, including opt-in and opt-out capabilities. At times, you also will receive mandatory communications from our Site when we deliver the services and Content that you request or need to advise you of important notices about the Site. In such cases, your only option for opting out of mandatory communications is to cancel your user account with us.
- Contact Information, Feedback, and Inquiries. When you submit feedback to us, contact us for support, or ask us questions, we may collect your first and last name, email address, telephone number, and/or other contact information in order to respond to your feedback, provide support, or answer your questions. This includes records and copies of your correspondence (including email addresses and phone numbers) with us, if any.
In accordance with applicable law, we will only use your personally-identifiable information in the following circumstances:
- In most cases, such as enabling you to use the Site and managing your user profile and account, because we have a necessary and legitimate interest in doing so to perform the Services you have requested, or to comply with your instructions or other contractual obligations between you and us;
- Because our legitimate interests, or those of a third party recipient of your personal information, make the processing necessary, provided those interests are not overridden by your interests or fundamental rights and freedoms;
- To comply with our legal obligations as well as to keep records of our compliance processes;
- Because you have chosen to publish or display your personal information on a public area of the Site;
- Because it is necessary to protect your vital interests;
- Because it is necessary in the public interest; and/or
- Because you have expressly given us your consent to process your personal information in a particular manner.
We collect personally-identifiable information for the following purposes:
- To enable you to access and use the Site, including to manage user information and accounts;
- To customize your experience, to conduct research and development to test and introduce new features and products, and to improve and monitor the effectiveness of our Site;
- For any other purposes that we specifically communicate to you when we collect that information with your consent, or for which we have a legitimate interest, including customer service and technical support;
- To market our products and services and to provide you with materials about offers, products, and services that may be of interest, including new content or Services, including tailoring content, advertisements, and offers, and to notify you of offers, products and services that may be of interest to you, for other purposes disclosed at the time that you provide your information, or otherwise with your consent;
- We may analyze, evaluate, and/or aggregate this information to help us understand your interests and the interests of our other users, to analyze trends, to optimize your user experience, and improve the Site; and
- We may share aggregated information about the Site and our users, without seeking additional consent, with third parties (including, without limitation, advertisers, media, and actual or potential partners or investors) for informational, marketing, and/or promotional purposes.
Other things you should know:
- We have feedback functionality on the Site that allows you to submit comments or suggestions. We may collect your name or username and email address in order to follow up with you or thank you for a suggestion.
Student Data Privacy. In accordance with the requirements of the Family Educational Rights and Privacy Act, 20 U.S.C. § 1232g, and its implementing regulations, 34 CFR part 99, as amended from time to time (collectively, “FERPA”), we do not use data about individually-identifiable student preferences gleaned from scanning student content to build user profiles or target ads to individual students.
3. Anonymous collection of information
We also collect or request anonymous or non-personally identifiable data and information from you that cannot identify you as an individual unless combined with personally identifiable information, which shall be segregated in a commercially reasonable manner intended to prevent re-identification. For example, our web server collects and stores the following general and aggregate information about your visits to our Site: the originating name of the domain from which you access the Internet; the date and time you access our service; the pages you visit; the Internet address of the website from which you linked directly to us; the name and version of the web browser software you are using. This information is collected automatically for a variety of audience and performance-related purposes, such as tabulating the number of visitors to our Sites in terms of new users, origin of referrers, popularity of pages, amount of use, and types of errors, in addition to making the Sites more useful to you.
We use “cookies,” which are small files stored on your computer's hard drive that are used to store and track personal information. Many browsers can notify you when you receive a cookie, giving you the option to accept it or not. By not accepting cookies, you may not be permitted to access certain information and some Site pages may not display properly.
When you visit our Site, the following categories of cookies will be set in your browser:
Strictly necessary cookies. These cookies are 1st party cookies and are essential in order to enable you to move around a site and use its features. Without these cookies services you have asked for cannot be provided.
Performance cookies. These cookies are 3rd party cookies and they collect information so that we can analyze how our visitors use our site. These cookies do not collect information that identifies you. All information these cookies collect is anonymous and is only used to improve how our site works.
Functional cookies. These cookies are 1st party cookies and they allow websites and applications to remember choices you make (e.g., such as your user name or the region you are in) and provide enhanced, more personal features. We may use information collected from functional cookies to identify user behavior and to serve Content based on your user profile. These cookies cannot track your browsing activity on other websites. They do not gather any information about you that could be used for advertising or to record where you’ve been on the Internet outside our site.
Analytics cookies. In order to keep our Site services relevant, easy to use and up-to-date, we use web analytics services and 3rd party cookies to help us understand how people use the site.
5. Using Information About You
When you provide your contact information to us, or request information about our products, we will enter your contact information in our database of inquiries. We use this information to:
- process sales and support requests;
- create instructor and learner accounts;
- send our newsletters and marketing emails;
- send the Learning Tool management related notifications; and
- process payments to Marketplace Simulations.
6. Third Party Websites
Additionally, the Site may use third-party service providers to provide various aspects of the Site. Each third-party service provider’s use of your personal information is dictated by their respective privacy policies. The Site currently uses the following third-party service providers:
- Google Analytics, Google Ads, www.google.com – Google Analytics service tracks website usage and provides information such as referring websites and user actions on the Website. Google Analytics may capture your IP address, but no other personal information is captured by Google Analytics. You can read our agreement with Google Analytics and privacy terms here: https://policies.google.com/technologies/partner-sites
Google Ads service provides ad service across Google site and its display network.
- ZenDesk.com – This service is our help desk platform.
- Growthdot.com – tracking email opens on Zendesk help desk platform
- Calendly.com – scheduling platform for instructor tours
- CloudFlare.com – this service is our CDN, Web Access Firewall and DDoS protection service for the www.marketplace-simulation.com site.
- RingCentral.com – this service is our phone service.
- ConstantContact.com – this service is our email marketing service.
- ActiveCampaign.com – this service is our email marketing service.
- CDN77.com – this service is our CDN service for the game.ilsworld.com site.
- KeyCDN.com – this service is our CDN service for the game.ilsworld.com site.
- Flexential.com – this site is out web hosting service.
- AlertLogic.com – this site is our intrusion detection service.
- Neustar, www.home.neustar – this is our DNS service.
- Oracle Cloud Infrastructure – this is our DNS service.
- DNSMadeEasy.com – this is our DNS service.
- Zoom.us – this is our web meeting service.
- CookiePro.com – this is our cookie consent service for marketplace-simulation.com domain web site.
- hCaptcha.com – this is our web forms bot protection service.
- Intermedia.net – This is our email and calendar service.
- eBridge, s.r.o., www.ebridge.sk - design and development and support and ticket troubleshooting of Marketplace Simulations.
- IL Center, www.il-center.com – distributor in the Netherlands, Belgium and Luxemburg
- iSpace Simulations Sp. z o.o., www.ispace.com.pl – distributor in Poland
- Marketplace Simulations UK Ltd, marketplace-simulation.co.uk - distributor in UK
- Mr. Alvydas Vitkauskas, www.vitkauskas.lt – distributor in Lithuania
7. Visiting our Site from outside the United States
8. Data Privacy Framework
In implementing the Data Privacy Frameworks Principles, Marketplace Simulations has agreed to subject its compliance to the full breadth of regulatory enforcement of the Federal Trade Commission (FTC) or any other statutory body empowered to enforce compliance with the Data Privacy Frameworks.
Marketplace Simulations acknowledges that EU, UK and Swiss individuals protected by the EU-U.S. and Swiss-U.S. Data Privacy Frameworks have the right to access or limit the use or disclosure of the personal information that we maintain about them. An EU, EEA, UK or Swiss individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct their query to [email protected]. If requested to remove data, we will respond within a reasonable timeframe.
If you are located in European Union (“EU”), the European Economic Area (“EEA”), UK, or Switzerland, we share this information with our applicable EU, EEA, UK, and Swiss distributor(s) to contact you with news and special offers to follow up on your request. You may always unsubscribe to these news or offers by removing your personally identifiable information using the method below or by clicking the “unsubscribe” link in any email.
Employees of Marketplace Simulations who have access to any of your personal information in connection with the Marketplace Simulations are not permitted to use this information for any other purpose than to carry out services on behalf of Marketplace Simulations. We share information about your participation in the Learning Tools with your instructor (professor) and/or other applicable faculty of your educational institution. We share your name with other users to help those users identify the proper game and team to join.
If you have any questions or complaints about our compliance with the Data Privacy Frameworks, please contact us using the contact information provided below.
In compliance with the EU-US Data Privacy Framework program’s Principles, Marketplace Simulations commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the DPF Principles. European Union individuals with DPF inquiries or complaints should first contact Marketplace Simulations using the contact information provided below.
Marketplace Simulations has further committed to refer unresolved privacy complaints under the DPF Principles to an independent dispute resolution mechanism, Data Privacy Framework Services, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for more information and to file a complaint. This service is provided free of charge to you.
If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf?tabset-35584=2
Pursuant to the Data Privacy Frameworks, Marketplace Simulations remains liable for the transfer of personal data to third parties acting as our agents unless we can prove we were not a party to the events giving rise to the damages.
General information about the Data Privacy Frameworks and the Data Privacy Frameworks Principles, as well as information about binding Data Privacy Frameworks arbitration, can be found at dataprivacyframework.gov.
9. Information We Share with Third Parties
In addition to using your information for the purposes described above, we may share your information with parties other than us or our users (the “Third Parties”), provided, however, we will provide you with prompt notice prior to any compelled disclosure, and shall reasonably cooperate with you so that you may have the opportunity to seek an appropriate protective order. In some cases we may request your permission before we share that information, but we reserve the right to share your information with Third Parties without prior notification or without soliciting additional permission when permitted by law. We discuss below those situations where we may share your information without requesting your further permission.
We may share your personal data in the following contexts:
- Disclosures with your consent. We may ask if you would like us to share your personal information with other unaffiliated third parties who are not described elsewhere in this Policy. We will only disclose your personal information in this context with your specific and express consent.
- Other users. We may disclose your personal data in response to your request to share Content with other users.
- Job Applications and Employment. If you apply for a job with us, we may disclose personal information necessary to process your application or employment. This may include, among other things, your contact information, your social security number, and employment history, in accordance with applicable law.
- Third Party Support. If you provide us with feedback, contact us for support, or ask us questions via web form, telephone, email, or other method allowed by our Services, we will collect and may disclose your name, email address, other contact information and other information to third parties as needed to respond to your feedback, request for support, or answer your question.
- Employees, business affiliates, and intermediaries. We disclose your personally identifiable information to our affiliates, subsidiaries, or divisions and their respective officers, directors, employees, accountants, attorneys, and agents, or with our business partners, all of whom are bound by all of the confidentiality and other data processing protections and practices described in this Policy, use your information strictly to carry out their job duties on a need-to-know basis, and only do so as required by law and as required by our legitimate interests.
- Our Vendors. Our Services may be developed and supported by third party vendors, who may, in the course of performing such services for us, have access to your personally identifiable information. Among other things, Service Providers may help us to administer the Services, support our provision of products and services requested by you, provide technical support, send marketing and promotions and communicate with you about our products and services, payment processing issues, and other legitimate purposes permitted by law. We require such vendors to maintain the confidentiality of your information, and take appropriate measures to keep it secure. We prohibit such vendors from using or sharing your information for any purpose other than in performing specific services for us required to maintain and update our Services.
- We also receive or disclose personal data about you from third parties, inside and outside of the EU/EAA, who are bound to obligations of confidentiality and required to perform processing with us or on behalf only for as long as a required by role and contract or business relationship with us. The types of personal data and third parties involved in these activities include: contact, financial, and transaction data with providers of technical, payment and delivery services, usage data with service providers who provide additional IT and system administration services, and business information and transaction data with professional advisers including, but limited to, lawyers and accountants who provide us with legal and accounting services. Please contact us with if you have any questions about the business and legal purposes for which we make such disclosures.
- Corporate Change. We may sell, transfer or otherwise share some or all of our assets in connection with a merger, reorganization or sale of assets, or in the event of bankruptcy, without your permission. In such an event, personally identifiable information may among the assets transferred.
- Aggregated Data. We may disclose aggregated, anonymized information about the Site and its users to third parties (including, without limitation, advertisers, media, and actual or potential partners or investors) for informational, new product development, marketing, and/or promotional purposes, without seeking additional consent from you, when such aggregated information does not identify you or any specific individual, as is the case with groupings of demographic data and customer preferences.
Please note the above list contains examples of personal data and information we may have concerning you and it does not necessarily mean that we do hold or disclose this information about you.
10. Individual Rights Under EU GDPR and UK GDPR
Absent exceptional circumstances, we offer you reasonable access to and control over your personal data at any time, at no charge. Please inform yourself of your rights by reviewing the list below. You may use the “Contact Us” details at the end of this Policy to exercise your rights and choices.
For those users in the European Union (EU) or the European Economic Area (EEA), or the United Kingdom (UK), we generally consider ourselves to be the “controller” of the “personal data” we collect and process, and we do so in compliance with the EU General Data Protection Regulation, 2016/679 (EU GDPR) or UK Data Protection Act 2018 (UK GDPR).
We try to respond to all legitimate requests regarding your personal information within one month. Occasionally, it could take us longer than a month if your request is particularly complex or you have made a number of requests. In such cases, we will notify you and keep you updated. The timeframes described here do not apply to our response times for addressing ordinary customer service and support requests unrelated to the exercise of personal information access rights.
Although we use commercially reasonable efforts to provide individuals with access to their personal information and to respond to their requests, there may be circumstances in which we need to ask you for more information to identify your account and may ask you to demonstrate your identity or we may be unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If we determine that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, we will take commercially reasonable steps to verify your identity before granting access to or making any changes to your personal information.
1. Request of access. You have the right to request a copy of the personal data that we hold about you, as well as to inquire about the origin, recipients, and purposes of that data. There are certain exceptions to this right, however, so that we may deny access to you as required by law or to protect the legal rights of others. You can request a download of your account information. To request a download, navigate to the “Request Account Info” button inside the Settings section of the Site.
2. Request correction. You have the right to request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Our goal is to keep your personal information accurate, current and complete. Please contact us if you believe your information is not accurate or changes. You may edit your account information via the Site.
3. Right to Erasure and Deletion of Your Personal Information. You may have a legal right (for instance, if you are located in the EU or EEA under the EU GDPR or in UK under UK GDPR) to request that we delete your personal information when it is no longer necessary for the purposes for which it was collected, or when, among other things, your personal information has been unlawfully processed. You may request to delete your chat history stored on our servers, for any reason, by contacting our Support Department. You may delete your entire user account, by selecting the appropriate option in the Site settings.
4. Right to Object. In certain circumstances, as permitted under applicable law, you have the right to object to processing of your personal information and to ask us to erase or restrict our use of your personal information. If you would like us to stop using your personal information, please contact us and we will let you know if are able to agree to your request.
5. Right to Portability. You have the right to request that some of your personal data is provided to you or an authorized third party in a commonly-used, machine-readable format (such as .txt). You can request a download of your account information. To request a download, navigate to the “Request Account Info” button inside the Settings section of the Site. If you require the direct transfer of data to another responsible party, this will only be done to the extent technically feasible.
6. Right to Withdraw Consent. If you have provided your consent to the collection, processing and transfer of your personal information, you have the right to fully or partially withdraw your consent. We attempt to comply with all reasonable and legitimate requests. As discussed above, you may modify the permissions and settings on your device and the Site to limit access to certain information. To withdraw your consent with respect to emails and other communications from us, please notify us or follow the opt-out links available in the communications sent to you. Once we have received notice that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing that override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. Withdrawal of consent to receive marketing communications will not affect the processing of personal information for the provision of our Services. However, changing the permissions and settings on your device or within the Site may cause certain features of the Site to stop functioning.
7. Updating Your Personal Information. If any of the personal information you have provided to us changes, please let us know. For instance, if your email changes, you wish to cancel any request you have made of us, or if you become aware of inaccurate personal information about you, please contact us to update your information. You may edit your account information via the Site.
We are not responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.
You may also have the right to make a EU GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en. If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law.
You may also have the right to make a UK GDPR complaint to the relevant Supervisory Authority. The UK GDPR Supervisory Authority is Information Commissioner's Office (ICO), https://ico.org.uk. If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law.
11. Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personally-identifiable information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Disclosure of Your Information for Third-Party Advertising. We do not share your personally-identifiable information with unaffiliated third parties for advertising purposes.
- Google Analytics Opt-out Option. If you do not want your information collected with Google Analytics, you can install the Google Analytics opt-out browser add-on. To opt-out of Google Analytics, visit the Google Analytics opt-out page (located at https://tools.google.com/dlpage/gaoptout) and install the add-on for your browser. For more details, visit the “Google Analytics opt-out browser add-on” page (located at https://support.google.com/analytics/answer/181881?hl=en).
Opt-out. You may “opt-out” and unsubscribe from our communications by clicking on the “unsubscribe link” found at the bottom of any emails you may receive from us or third party affiliates or by contacting us directly at the postal address listed at the end of this policy.
Do Not Track (“DNT”). DNT is a privacy preference that users can set in certain web browsers and devices. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
12. International Transfers
Our company headquarters are located in Knoxville, Tennessee, United States. We store your personal data and information on servers in the United States, so if you access the Services or reside outside of the United States, please be aware that your personal data and information is transferred to, stored, and/or processed in these locations. While the data protection, privacy and other laws of the United States might not be as comprehensive as those in your country, we take necessary and appropriate steps to protect the security and privacy of your personal information. When you use or request Services from us, we require your consent for the collection, storage, processing and transfer of your personal information to our facilities in the United States and those third parties or other countries with whom we may share it as described in this Policy.
13. Data Retention Practices
We will retain your personal data for as long as needed to fulfill the purposes for which it was collected and to provide the Services to you. As a result, data retention periods may depend upon the feature of the Site for which the data was provided.
We keep most personally-identifiable information on our servers for a period of not more than 2 years for students located in EU, EEA, UK; not more than 4 years for students located outside EU, EEA, UK; not more than 6 years since their last activity for professors located in EU, EEA, UK; not more than 10 years since their last activity for professors in countries outside of EU, EEA, UK unless you reasonably request for the information to be deleted sooner or we have a reason to retain it that is protected by law. With regard to credit card payments, our retention process differs, because such payments are all timely processed using third-party gateways Authorize.net and PayPal.com.
We also will retain and use your personal data as long as necessary to comply with our business requirements, legal obligations, resolve disputes, protect our assets, provide our services, and enforce our agreements. We only collect this data on an aggregated basis, and in a manner which does not reveal any personal data or information that identifies any individual user. This data helps us to better understand our users’ interests, analyze trends, and customize the user experience.
When we no longer have a purpose to retain your personal data, we will use commercially reasonable efforts to securely destroy your personal data in accordance with applicable law and our policies. In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
14. Data Security
We maintain appropriate technical and organizational measures to prevent your personal information under our control from being accidentally lost, used or accessed in an unauthorized manner, altered or disclosed during collection, storage, and processing. All information you provide to us is stored on our secure, limited access servers behind firewalls. Your personal data and information is password-protected so that only you can log in to your account. Any additional safeguards used to protect personal information will depend on the sensitivity of the personal information, the amount, distribution and format of the information, and the method of storage.
By using the Site or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice within the Site. Access to your account and personal data and information is restricted within our organization to employees and trusted partners that need access to your personal information in order to correspond with you and provide the products and/or services that you requested from us.
While our security measures seek to protect your personal information in our possession, no security system is perfect and we cannot guarantee that your personal information will remain absolutely secure in all circumstances or that any privacy settings or security measures used in connection with the Services cannot be circumvented. Therefore, we cannot guarantee that unauthorized third parties will not be able to circumvent those measures or other safeguards in use, or access and/or use your personal information for improper purposes.
The majority of communications on our Services, including any submissions through available forms, are sent encrypted through the standard HTTPS protocol and may be delivered using regular e-mail. Information is not sent over the unencrypted HTTP protocol. E-mail, while convenient, does pose some risks (e.g., e-mail is not a secure form of communication, is unreliable, can be forwarded, etc.). Any transmission of information that you make through our Services is at your own risk.
The safety and security of your personal information also depends on you. Where you use a password for access to restricted parts of the Services, you are responsible for keeping the password confidential. Do not share your password with anyone else. Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.
If a security breach causes an unauthorized intrusion into our Services or systems that compromises your data, we will notify you and any applicable regulator when we are required to do so by applicable law.
15. Children’s Privacy
The services are not directed to, nor do we knowingly collect, personal information from minors under 13 years of age. The services are not directed to, nor do we knowingly collect, personal information from minors under 18 years of age or the locally-applicable legal age of majority without a lawful guardian or parent’s lawful consent. If you learn that a minor, or an administrator at the school, where the minor is enrolled, has provided us with personal information without such consent, you may alert us at [email protected]. If we learn that we have unlawfully collected any personal information from minors, we will promptly delete such information and terminate the minor’s account.
16. Your California Rights
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits you, if you are a California resident, to request and obtain from us once a year, free of charge, information about the personally identifiable information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared such information. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information at the end of this policy and clearly label your request “Shine the Light Inquiry”.
Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response. Also note that under California law, businesses are only required to respond to such requests once during any calendar year within the time prescribed by law in response to reasonable and verifiable requests.
18. Contact Us
If you have questions or comments about this Policy, wish to access personal information we hold about you, believe the personal information we have about you is incorrect, or wish to lodge a complaint with us about how we have handled your personal information, please use the contact details below and we will do our best to assist you:
Attn: Privacy Director
P.O. Box 23679
Knoxville, TN 37933
Email address: [email protected]
Telephone number: +1 (865) 522 1946
Regarding the EU GDPR and UK GDPR issues or queries, contact us at https://prighter.com/q/11648383.
Last update 10/18/2023