Last Updated: May 4, 2023
Edgi Learning, Inc. (“Edgi Learning”, “we
”) provides information about how we use, collect, and process your personal data in connection with our website https://www.edgilearning.com
(together with the features, functionalities, browser extensions and other services available through the website, our “Website
”) and Edgi Bot, Edgi Librarian aand all other programs and services we provide (our “Services
”). Our Website and Services are collectively referred to herein as our “Offerings
You can access and interact with our Offerings in many ways, including from a computer or mobile device. This Policy applies regardless of how you access or interact with our Offerings. Depending on how you access, participate in, interact with or use our Offerings, there may be some cases where we need to provide you with additional information about how we collect, use, protect or disclose your Personal Data and/or what options you have regarding our collection, use or disclosure of your Personal Data. We may provide this additional information through notices on our Website or via direct communications with you. If we do this, unless we tell you otherwise, the additional information will apply in addition to what is described in this Policy.Please read this Policy carefully. If you do not want us to collect, use or disclose your Personal Data in the ways described in this Policy, please do not access, participate in, interact with or use our Offerings, provide us with your Personal Data or authorize any third party to make your Personal Data available to us. By accessing, participating in, interacting with or using our Offerings, you acknowledge that you understand that we may use your Personal Data as described in this Policy. Please note, as described in this Policy, we may receive your Personal Data from third parties that have not expressly told you that they will provide your Personal Data to us. If you have any questions about how we collect, use, protect or disclose your Personal Data in connection with our Offerings, please contact us by email at firstname.lastname@example.org. PERSONAL DATA WE COLLECT
Our primary goals in collecting Personal Data are to improve our Offerings, conduct our relevant business operations, communicate with people and enable visitors to our Website to easily navigate and enjoy our Website and Services.
When we refer to “Personal Data
” in this Policy, we mean information that identifies, relates to, describes or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a specific person. This might be information that directly identifies someone, such as their name, or it may be information that identifies someone only when combined with other information available to us. Please note, except as provided under applicable laws, Personal Data does not include information that is publicly available through government records or information that has been deidentified or aggregated in a way that it cannot be used to identify a specific individual.Categories of Personal Data We Collect
Depending on how you access, participate in, interact with or use our Offerings, we, or third parties acting on our behalf, may collect the following categories of Personal Data about you:
- Identifiers and contact information, such as your real name, alias, email address, telephone number, postal address, physical address, date of birth, unique personal identifier, government-issued identification number, online identifier, profile picture, IP address and other similar information;
- Demographic information, such as your age, gender, ethnicity, national origin, grade level, and other similar information;
- Internet and other similar network activity information, such as your browsing history, search history, interactions with our Website and online advertisements and other similar information;
- Information contained in audio and video recordings captured during certain sessions on or in connection with our Offerings, such as your likeness, your voice, your responses and other similar information;
- Financial information, such as your credit card number, debit card number, digital wallet information and other similar information;
- Communication information, such as information contained in voice mails, chats, emails, and other similar information;
- Transactional information, such as information about purchases you have made or participated in through our Offerings and other similar information;
- Location information, such as where you live, where you are located and other similar information;
- Other information you provide to us or that others provide to us about you.
Other Information We Collect
Depending on how you access, interact with or use our Website and Offerings, the Usage Data that we, or third parties acting on our behalf, may collect may include:
- Device information, such as the IP address, general geographic location, operating system, browser type, language preferences, mobile phone number, device identifier and other similar information associated with a device used to access, use, or interact with our Website;
- Information about interactions with our Website or Offerings, such as messages to and from Edgi Bot, links that are clicked, pages or screens that are viewed, access and session times, interactions with emails we send and other similar information associated with a device used to access, use, or interact with our Website or Offerings;
- Information about internet and network activity, such as websites visited, search engine results and similar information associated with a device that accesses, interacts with or uses our Website;
- Other information automatically collected by cookies and other technologies on our Website; and
- Any other information that a browser or device automatically sends whenever connected to a website or an application.
HOW WE COLLECT PERSONAL DATA
A large portion of the Personal Data we, or third parties acting on our behalf, collect is collected directly from our users and others who provide their Personal Data to us directly. In some cases, we may collect Personal Data from third parties in the ways described in this Policy.
Directly from You
When you access, participate in, use, or otherwise interact with our Offerings, or otherwise engage with us in connection with our Offerings, such as joining our waitlist, we may ask you to provide certain Personal Data. Some of the Personal Data we request with respect to certain features of our Offerings may not be required, however, we will let you know if specific Personal Data is required to use those features. If you do not provide us with the Personal Data required to use a certain feature of our Offerings, that feature will not be available to you.
You may give us your identity and contact data, profile data, transaction data and other information when you join the waitlist, register with us, sharing details about our Services or by corresponding with us by post, phone, email, SMS, social media or otherwise. This includes personal data you provide when you give us feedback or contact us.
From Third Parties
We, or third parties acting on our behalf, may receive Personal Data about you from third parties, such as online and offline sources, entities affiliated with us, our service providers, social media platforms, advertising networks and other public or commercial sources (collectively, “Third Party Services”). In some cases, you may be able to revoke our access to your Personal Data and other content and information we receive from a Third Party Service by changing the appropriate settings for your account with that Third Party Service.
- We, or third parties acting on our behalf, may receive Personal Data about you from third parties that provide services to us through or in connection with our Offerings (“Operational Service Providers”). Operational Service Providers may include, without limitation, service providers who host our Website, shipping providers, and parties that provide us services related to emails and other communications we send and receive.
- We, or third parties acting on our behalf, may receive Personal Data about you from our related business entities or affiliates (our “Affiliates”). This Personal Data may include, without limitation, information related to your access, use or interaction with our Affiliates and/or the services, products, and other things they provide.
- We, or third parties acting on our behalf, may also receive Personal Data about you from other third parties, such as other individuals and entities that participate in our Services and those that refer you to our Offerings.
- Please note, we may combine the Personal Data and other content and information we receive about you from multiple sources, including, without limitation, Personal Data we collect directly from you and one or more third parties.
HOW WE COLLECT USAGE DATA
We, and third parties acting on our behalf, collect Usage Data in a variety of ways. Some Usage Data, such as the IP address of a device attempting to access, use or interact with our Website, is necessary for us to make certain portions of our Website available. Other Usage Data, such as information about what features of our Website are popular, help us to improve and advertise our Offerings. The primary ways Usage Data is collected in connection with our Website are through:
- The systems we use to make our Website available to you. When you access, use, or interact with our Website, these systems automatically record certain information that your browser or device sends whenever you visit a website or utilize an online application as well as information about how long your device is connected to our Website and the activities that device engages in while connected.
- Other tracking technologies, such as web beacons, clear gifs, and pixel tags. These technologies may be used on or in connection with our Website, including, without limitation, in emails we send. We may use these technologies to deliver cookies, count visits, understand usage, and observe data on email delivery, open rates, click rates, bounces, unsubscribes and other information.
Please note, we have not yet developed a response to browser “Do Not Track” signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals in light of industry developments or legal changes.
HOW WE USE PERSONAL DATA
We use Personal Data to maintain our waiting list and for various purposes related to operating and improving our Offerings and conducting our Services. The primary purposes for which we use Personal Data are:
- Non-Marketing Purposes – we may use the Personal Data we, or third parties acting on our behalf, collect for non-marketing purposes, including: (1) operating and improving our Offerings; (2) validating your identity; (3) carrying out our obligations and enforcing our rights arising from any contracts we have entered into, including, without limitation, any contracts between you and us; (4) sending you communication to provide you with alerts and updates about your engagement with our Offerings, including your status on the waitlist; (5) conducting statistical or demographic analysis; (6) complying with legal and regulatory requirements; (7) customizing your experience with our Offerings; (8) protecting and defending Edgi Learning against legal actions or claims; (9) preventing fraud; (10) satisfying contractual obligations; (11) cooperating with law enforcement or other governmental agencies for purposes of investigations, national security, public safety or matters of public importance when we are legally required to do so or believe that disclosure of Personal Data is necessary or appropriate to protect the public interest; (12) assessing and supervising coursework; (13) providing online synchronous teaching and learning opportunities, including live and recorded audio and video teaching sessions and forums; (12) those purposes in which you authorize or instruct us to use your Personal Data; and (13) other business purposes permitted under applicable law.
- Marketing Purposes – we may use the Personal Data we, or third parties acting on our behalf, collect for marketing purposes, including to notify you about our other programs and courses and invite you to relevant information sessions, via e-mail and other means, all subject to our compliance with applicable laws (“Marketing Purposes”). We may also link Personal Data (including your name, mobile phone number, and email address) with other information (including information we automatically collect as described in this Policy) and use such linked information for Marketing Purposes. If you do not want us to use your Personal Data for marketing purposes, you may opt-out in accordance with the “Managing Your Personal Data” section below.
We will not collect additional categories of Personal Data or use the Personal Data we, or third parties acting on our behalf, collect in connection with our Offerings for materially different, unrelated or incompatible purposes without providing you notice.
Please note, we may use and disclose aggregated, anonymized or de-identified information collected in connection with our Offerings and other information that does not identify any individual (“Anonymized Data”) for any lawful purposes, which may include, without limitation, purposes not described in this Policy. Except as otherwise required under applicable laws, our use and disclosure of such Anonymized Data is not subject to this Policy.
SHARING PERSONAL DATA WITH THIRD PARTIES
To operate our Website and provide our Services, we may share certain Personal Data that we, or third parties acting on our behalf, have collected, with certain third parties. The third parties that we may share Personal Data with include:
- Our Service Providers in connection with the services they provide to us, including, without limitation, order fulfillment, marketing, data hosting, payment processing and fraud protection and prevention. We require these Service Providers to exercise reasonable care to protect your Personal Data and restrict their use of your Personal Data to the purposes for which we provided to them.
- Government and law enforcement individuals or private parties where necessary to enforce and comply with the law. To the extent permitted under applicable law, we may disclose any Personal Data and other information to government or law enforcement officials or private parties as we believe is necessary or appropriate to investigate, respond to and defend against legal claims, for legal process (including subpoenas), to protect our property and rights of those of a third party, to protect us against liability, for the safety of the public or any person, to prevent or stop any illegal, unethical, fraudulent, abusive or legally actionable activity, to protect the security and integrity of our Website and any equipment used to make our Website available or to comply with applicable laws.
- Any third party to whom you consent and/or instruct us to provide your Personal Data.
THIRD PARTY INFORMATION COLLECTION
Based on the nature of our Offerings, third parties may collect information from or about you through or in connection with our Offerings. In addition to other information provided in this Policy, including, without limitation, the section titled “How We Collect Usage Data” the categories of third parties that may collect information about you through or in connection with our Offerings include:
- Third parties whose content is linked to on our Website. Any links to other websites, applications or other third party content on our Website, are not an endorsement, authorization, or representation of our affiliation with that third party and we are not responsible for the content, privacy and security policies and practices of any third party. We encourage you to read the privacy policies or statements applicable to any third party websites, applications, or content you access.
- Third party platforms. Certain features of our Offerings use services provided by third parties. These third parties may collect certain Personal Data about you and your interactions with us and our Offerings.
HOW TO MANAGE YOUR PERSONAL DATA
We offer you several choices with respect to how we use your Personal Data. The mechanisms available to you to control our use of your Personal Data are:
- To update any Personal Data you have provided us, update your preferences or otherwise contact us about our use of your Personal Data, please email us at email@example.com.
- To manage the marketing and other promotional email communications you receive from us, you can opt-out of receiving such communications by following the unsubscribe instructions contained in most text messages from us. Your unsubscribe request or email preference changes will be processed promptly, though this process may take several days. During that processing period, you may receive additional marketing and other promotional emails from us. Please note, opting out of these communications will only apply to marketing and other promotional emails and will not apply to any email or other communications we send you for non-marketing purposes, including, but not limited to, emails and other communications about your orders and other interactions with our Website.
- To request deletion of your Personal Information, please submit a request to us by emailing us at firstname.lastname@example.org. Only you, or a party that you authorized on your behalf, may make a request related to the deletion of your Personal Data. You may also make a request on behalf of your minor child. Your request for deletion must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
- We cannot respond to your request or delete your Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
Making a request does not require you to create an account with us and we will only use Personal Data provided in connection with a request for deletion to verify the requestor’s identity or authority to make the request.
We endeavor to respond to deletion requests within a reasonable time period after we receive a deletion request. If we are unable to fully comply with your request to delete your applicable Personal Data, our response will explain the reasons why we are unable to fully fulfill your request.
If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
PROTECTING YOUR PERSONAL DATA
We are committed to protecting the security of your Personal Data. We use commercially reasonable safeguards to maintain the security and privacy of Personal Data we collect and use in connection with our Website. Nevertheless, when disclosing Personal Data, you should remain mindful that there is an inherent risk in the transmission of information via the internet and mobile platforms. Although we take precautions to protect against the risk of unauthorized access to your Personal Data, we cannot guarantee the security of any information, including your Personal Data, that you disclose online and you do so at your own risk.
RETENTION OF PERSONAL DATA
We reserve the right to retain any Personal Data as long as it is needed to: (1) fulfill the purposes for which we collected the Personal Data; and (2) comply with applicable law.
We do not direct or target our Offerings to children under the age of 13. If we learn that we have collected the Personal Data of anyone under the age of 13, we will take appropriate steps to delete this information. If you are a parent or guardian of someone under the age of 13 and discover that your child has submitted Personal Data to us, please contact us at email@example.com. We will make reasonable efforts to remove such information from our databases.
CALIFORNIA PRIVACY RIGHTS
If you are a California resident, under California’s Shine the Light Law (California Civil Code Section 1798.83) you have the right to request the following information regarding our disclosure of your personal information to third parties for direct marketing purposes: (1) the categories of personal information we disclosed to third parties for their direct marketing purposes during the preceding calendar year; (2) the names and addresses of the third parties that received the information; and (3) if the nature of the third party’s business cannot be determined from their name, examples of the products or services they marketed. This information may be provided in a standardized form that is not specific to you.
You are permitted to obtain this information from us once a year, free of charge. To make such a request, please submit your request in writing to:
Attn: CA Privacy Rights Request
55 Washington St, Ste 740
Brooklyn, NY 11201
EUROPEAN USER RIGHTS
If you are located in the EU, Switzerland, or the United Kingdom, you have certain rights with respect to your Personal Data. Following is a summary of those rights and additional information applicable to our collection and use of your Personal Data.
When you provide us with your Personal Data in connection with our Offerings, we serve as a data controller. When we act as a data controller we determine how your Personal Data will be utilized, in accordance with this Policy.
Legal Basis for Processing
We rely on several legal bases to process your Personal Data. These legal bases include where:
- The processing is necessary to perform our contractual obligations, such as to provide you with access to our Offerings;
- You have given your prior consent, which you may withdraw at any time (such as for marketing purposes or other purposes we obtain your consent for from time to time);
- The processing is necessary to comply with a legal obligation, a court order, or to exercise or defend legal claims; and
- The processing is necessary for the purposes of our legitimate interests, such as improving, personalizing, and developing our Offerings, marketing new features or products that may be of interest, and promoting safety and security as described above.
If you have any questions about or would like further information about the legal bases we rely on to collect and use your Personal Data, please contact us at firstname.lastname@example.org.
Rights Under the General Data Protection Regulation
If you are located in the EU, Switzerland, or the United Kingdom, you have the following rights in respect of your Personal Data that we hold:
- Right of access. The right to obtain access to your Personal Data.
- Right to rectification. The right to obtain rectification of your Personal Data without undue delay where that Personal Data is inaccurate or incomplete.
- Right to erasure. The right to obtain erasure of your Personal Data without undue delay in certain circumstances, such as where the Personal Data is no longer necessary in relation to the purposes for which it was collected or processed.
- Right to restriction. The right to obtain the restriction of the processing undertaken by us on your Personal Data in certain circumstances, such as where the accuracy of the Personal Data is contested by you, for a period enabling us to verify the accuracy of the Personal Data.
- Right to portability. The right to portability allows you to move, copy, or transfer Personal Data easily from one organization to another.
- Right to object. You have a right to object to processing based on legitimate interests and direct marketing.
If you wish to exercise one of these rights, please email us at email@example.com. You also have the right to lodge a complaint with your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
Retention of Personal Data
We reserve the right to retain any Personal Data as long as it is needed to: (1) fulfill the purposes for which we collected the Personal Data; and (2) comply with applicable law.
Transfers of Personal Data
If you are located in the EU, Switzerland, or the United Kingdom, the Personal Data we collect may be stored and processed in any country in which we or our affiliates, suppliers, third party electronic payment processors, and/or agents maintain facilities, including, without limitation, the United States of America. The United States of America has not sought nor received a finding of “adequacy” from the EU, Switzerland, or the United Kingdom. We rely on appropriate safeguards and derogations for specific situations as set forth in applicable laws to protect Personal Data transferred from the EU, Switzerland, or the United Kingdom to third countries and international organizations.
Obligations to Data Protection Authorities (DPAs)
We will respond diligently and appropriately to requests from DPAs about this Policy or compliance with applicable data protection privacy laws and regulations. We will, upon request, provide DPAs with names and contact details of the individuals designated to handle this process. With regard to transfers of Personal Data, we will (1) cooperate with inquiries from the DPA responsible for the entity exporting the data and (2) cooperate with its decisions, consistent with applicable law and due process rights. With regard to transfers of data to third parties, we will comply with DPAs decisions relating to it and cooperate with all DPAs in accordance with applicable legislation.
Personal Data collected in connection with the use and operation of our Offerings is stored and processed in the United States. If you access, use or otherwise interact with our Offerings or otherwise engage with us from outside the United States, please be advised that your personal information may be initially collected by servers located in the United States or, if initially collected outside the United States, transferred to the United States. Please note, the United States has not been assessed as having adequate privacy laws by some countries and economic regions.
CHANGES AND UPDATES TO THIS POLICY
Because the methods used to protect your Personal Data and the services we provide are continually evolving, this Policy may change at any time. Unless otherwise noted, those changes will be effective as soon as they are posted. If changes are made to this Policy, we will make it known on our Website or by email and will indicate the last date it was updated above. Please check back periodically to see if our Policy has been updated.
Your continued use of our Offerings after any changes to this Policy become effective, constitutes your continued acknowledgement that you understand that we may continue to use your Personal Data as described in this Policy.
We welcome your questions, comments and concerns about privacy. Please email us at firstname.lastname@example.org with any questions or feedback you have pertaining to our privacy practices.