Privacy Notice

Last Updated: May 3, 2021

1. Introduction

1.1 This Privacy Notice provides information about how Edgi Learning, Inc., a Massachusetts corporation with a business address of 180 Elm Street, Suite I #184, Pittsfield, Massachusetts 01201, (“Edgi Learning”, “we”, “our”, “us”) collects and processes the personal data of individuals (“you”, “your”) who visit and/or interact with our website https://edgilearning.com/ (the “Website” or “Site”) and who enroll in an online course of study offered by us (a “Course”), including our adaptive training sessions for Courses and live sessions (the “Services”), and to all subsequent correspondence or communications with those people, whether by email, telephone or by mail.

1.2 We reserve the right to amend this Privacy Notice at any time, for any reason, without notice to you, other than the posting of the amended Privacy Notice on the Website. We recommend that you check the Website often, referring to the date of the last modification listed at the top.

1.3 It is important that you read this Privacy Notice so that you are aware of how and why we are using your personal data.

2. How we collect your personal data

2.1 We may receive your personal data through various means including Direct interactions:

• You may give us your identity and contact data, profile data, transaction data and other information by creating and managing your user profile account, participating in online discussion forums, filling in website forms, 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 submit coursework, give us feedback or contact us.

2.2 We may receive your personal data through various means including Automated technologies:

• As you browse and interact with the Website, we collect browser data. We collect this personal data by using cookies and other similar technologies. Please see our Cookies Policy for further details.

2.3 Cookies: A cookie is a simple text file that is stored on your computer or mobile device when you visit a website. When you visit the website again, or visit another website which recognizes that cookie, your device is able to communicate with the website and the website can read the information held in that cookie. Only that server will be able to retrieve or read the contents of that cookie. Each cookie is unique to your web browser. It will contain some anonymous information such as a unique identifier as well as the website name. Cookies may be set by the website you are visiting (“first party cookies”) or they may be set by other websites who run content on the page you are viewing (“third party cookies”).

Cookies have various purposes, including letting you navigate between pages efficiently, storing your preferences, and generally improving your experience of a website. Most websites you visit will use cookies to improve your user experience by enabling that website to “remember” you, either for the duration of your visit (using a “session cookie”) or for repeat visits (using a “persistent cookie”).

We may use the following first party cookies and third party cookies on our Site:

• Strictly Necessary cookies: These cookies are essential in order to enable you to move around the Site and use its features, such as accessing secure areas of the Site. The Site needs Strictly Necessary cookies for it to work. If you remove or disable these Cookies, we cannot guarantee that you will be able to use our Site.

• Analytical/performance cookies: These cookies provide generic statistics on the use of our website by allowing us to recognize and count the number of visitors and to see how they move around and access the site. This helps us to improve the way the Site works, for example, by ensuring that users find what they are looking for easily.

• Functionality cookies: These are used to recognize you when you return to our Site, and remember your preferences.

• Targeting cookies: This type of cookie records your visit to our Site, the pages you have visited and the links you have followed or come into the Site on. Depending on the pages that you have visited, the cookie may trigger advertising for us on third-party websites either related or unrelated to our business. We may use this information may also be used for re-targeting or offer based promotional uses by us from time to time.

Except for Strictly Necessary cookies and any others which are essential for the functioning of this Site, you can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. You can set these preferences on your browser settings. However, each browser is different so check your browser’s Help menu to learn how to modify your cookies. This may prevent you from taking full advantage of this Site.

We employ commonly used third-party analytic services that may automatically collect and store information about visits to the Site. We do not have direct control over the tools these third-party analytic services use to collect data. We use this information to get a better sense of how our Site is being used over time so that we can improve them and make them more relevant to users and in ways described herein.

Please note that:

• Many of the interactive functions offered by the Site are dependent on cookies and disabling or blocking cookies may impact the functionality of the Site or result in an inferior web experience.

• If you’ve chosen to block third-party cookies on your browser, your cookie preferences won’t carry over from the Site and vice versa.

• We have no access to or control over any cookies or other devices that are used by any third party advertisers or ad servers on the Site.

If your personally identifiable information changes, or if you no longer wish us to possess your information, you may request correction, updating, or deletion of your information by emailing us at support@edgilearning.com.

3. Why we process your personal data

3.1 Subject to applicable law, your personal data may be stored and processed by us for purposes detailed in the following table:
Purpose for processing personal data Categories of personal data
Applications and Enrollments •Identity data such as name, title
•Contact data such as addresses, telephone numbers, and personal email addresses.
•Date of birth (Grade Level)
•Gender
•Nationality and country of residence
Finance in order to process your payments •All information is collected by third party service providers.
User profiles •Identity data such as username, profile photo, etc.
•Social media accounts
Providing the Services to student participants •Online synchronous teaching and learning by student participation
•Live and recorded audio and video teaching sessions and forums.
•Assessment and supervision of coursework
•Surveys and student feedback
Discussion forums •Username
•Profile picture
Marketing
•To inform you of other programs and courses
•To invite you to information sessions relevant about other courses and programs we provide
•To carry out marketing analysis, for example we look at what you have viewed on our Website and what your preferences are to improve the relevance of our marketing
•Your preferences in receiving marketing communications from us
•If you would prefer that we do not send such communications to you, please follow the opt-out links on any marketing message or contact us at support@edgilearning.com.
Browser data •Internet protocol (IP) address used to connect your computer to the Internet
•Your browser type and version
•Time zone setting
•Browser plug-in types and versions
•Operating system and platform
•How often you visit the Website
•Website performance data

4. Third party information 

4.1 Other individuals’ personal data

• Where you provide us with personal data relating to other people, you represent and warrant that you will only do so in accordance with applicable law, including data protection laws. You will ensure that before doing so, the individuals in question are made aware of the fact that we will hold information relating to them and that we may use it for any of the purposes set out in this privacy statement, the Website Terms of Use, and where necessary you will obtain their consent to our use of their information. You will provide anyone that you provide us with personal data about with a copy of this Privacy Notice. We may notify those individuals that you have provided their details to us.

4.2 Information collected through third-party links and content

This Website may include links to other websites and other content from third party businesses and can offer direct interaction with external websites, networks or platforms that are outside our control. These third-party businesses may use cookies, web beacons or other similar technology to collect information about you. We do not have access to or control over these third parties or the cookies, web beacons or other technology that these third parties may use. We are not responsible for the security, privacy of the information collected by these third parties or the privacy practices of these third parties or the content on any third-party website. You are encouraged to review the privacy policies of the different websites you visit.

5. Disclosure of your personal data

5.1 We reserve the right to disclose your personal data to third parties:

• if we are under any legal or regulatory duty to do so; and
• to protect our rights or the safety of us, our personnel, users or others.

5.2 We also use third party service providers as our processors to only hold and use personal data on our behalf in order to provide us with a service. We may also disclose personal data to our professional advisors and experts in order to obtain their assistance in carrying out our services and our activities. We require these parties to keep your personal data confidential and secure and to protect it in accordance with the law. They are only permitted to process your personal data for the lawful purpose for which it has been shared and in accordance with our instructions.

6. Security of your personal data

6.1 Edgi Learning is committed to maintaining the security of your personal data it processes.  Edgi Learning maintains appropriate physical, procedural, organizational and technical security measures intended to prevent loss, misuse, unauthorized access, disclosure, or modification of your personal data under Edgi Learning’ control.  We also limit access to your personal data within our organization and to third parties that need access to your information in provision of service to us. They will only process your personal data on our instructions and are required to protect personal data. If you have reason to believe that your personal data is no longer secure, please support@edgilearning.com immediately. 

6.2 Please be aware that when you transmit information to us or to our service provider over the internet or another telecommunications network this can never be guaranteed to be 100% secure. For any payments which we take from you or pay to you online we will use a recognized third party online secure payment system, and we are not responsible for the security of this system. You should contact these third parties for information about the security of these internet, telecommunications systems or payment systems if you need further information.

6.3 We cannot guarantee against any loss, misuse, unauthorized disclosure, alteration or destruction of data but we take reasonable steps to prevent this from happening. We have put in place measures to protect the security of your personal data and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Video recordings

7.1 In connection with the Services, we may record audio, video or otherwise capture your and others’ participation in Course activities (“Recordings”). We may share Recordings with our employees and agents as well as students, teachers, parents, and others in our discretion.  We use Recordings, among other things, for classroom learning, to provide feedback to teachers, for customer support, and for compliance purposes. We will obtain additional parental consent before we use any Recordings for promotional purposes. We utilize reasonable means to restrict the use of Recordings; however, we cannot control or monitor what such third parties ultimately do with Recordings, and disclaim all responsibility with respect to such uses.

8. Retention of your personal data

8.1 We endeavor to ensure that personal data is kept as current as possible and that irrelevant or excessive data is deleted or made anonymous as soon as reasonably practicable. We generally retain personal data for as long as is required to satisfy the purpose for which it was collected. We are required to keep certain types of information for a specific period of time in order to comply with legal requirements. Some of your personal data may need to be retained because of circumstances such as a legal dispute or regulatory investigation, which would not normally be subject to retention.

9. Updating your personal data

9.1 You are responsible for notifying us of any changes to your personal data that you provide to us.

10. Children

10.1 Our Website and Service are not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Website or Service. If you are under 13, do not use this Website or Service or provide any information about yourself to us, including your name. If a parent or guardian is made aware that a child under the age of 13 has provided us with personally identifiable information through any point of contact, we ask to be contacted by email via the contact page and we will delete the information.

11. Additional Notice for California Consumers

This portion of our Privacy Policy applies to California consumers only.

11.1 Personal Information Collected on California Consumers in the Last Twelve Months

We collect information from users, as described in our Privacy Policy. The “Personal Information,” as defined in California Civil Code § 1798.140(o), we have obtained on California residents within the last twelve months includes the following:

• Identifiers such as a real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers.

• Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

• Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.

• Geolocation data (excluding real time GPS information).

• Audio, electronic, visual, thermal, olfactory, or similar information.

• Professional or employment-related information.

• Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).

• Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

11.2 Our Use of Personal Information for Business Purposes in the Last Twelve Months

We use the Personal Information we collect, identified in each of the above categories, for the business purposes disclosed within the Privacy Policy. These business purposes include the following:

• Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.

• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

• Debugging to identify and repair errors that impair existing intended functionality.

• Short-term, transient use, provided the personal information that is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.

• Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.

• Undertaking internal research for technological development and demonstration.

• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

11.3 Sharing of Personal Information in the Last Twelve Months

Disclosures of Personal Information on California Consumers for Business Purposes: Within the last twelve months, we have disclosed Personal Information identified in the above categories only (i) for exempt activities, as part of a business-to-business transaction, (ii) at your express request, or (iii) for our business purposes. 

12. California Rights and Choices

If you are a California resident, you have certain legal rights related to your Personal Information. Except as otherwise provided by applicable law, you may exercise the following rights for purposes of the Personal Information covered by our Privacy Policy.

12.1 Right to Know/Portability

You have the right to request that we disclose to you certain information about Personal Information we collected about you within the past twelve months. Once we confirm your verifiable request, we will disclose to you:

• the categories of Personal Information we have collected about you;

• the categories of sources from which the Personal Information is collected;

• our business or commercial purpose for collecting Personal Information;

• the categories of third parties with whom we share Personal Information; and

• the specific pieces of information we have collected about you.

12.2 Right to Opt Out

We do not offer a right to opt out because we have not sold any Personal Information described in this Privacy Policy to third parties within the previous twelve months and will not sell Personal Information within the meaning of the CCPA.

12.3 Right to Deletion

You have the right to request deletion of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we confirm your verifiable request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;

• detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;

• debug products to identify and repair errors that impair existing intended functionality;

• exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;

• comply with the California Electronic Communications Privacy Act;

• enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;

• comply with a legal obligation; or

• make other internal and lawful uses of that information that are compatible with the context in which you provided it.

12.4 Right to Non-Discrimination for Exercise of a California Privacy Rights

We will not discriminate against you because you exercise any of the above rights, or any other rights under the CCPA. Specifically, if you exercise your Rights, we will not deny you Services, charge you different prices or rates for Services or provide you a different level or quality of Services.

12.5 How to Submit A Request

You may submit a request to exercise the rights listed above by:

• emailing us at support@edgilearning.com.
• In your request, please include (1) full name used to create your account; (2) email with which you created your account; (3) phone number in case we need to contact you to securely verify your request; (4) whether you are requesting how your information is used and/or to delete your personal information.

12.6 Verifiable Request

As required under applicable law, we take steps to verify your identity before responding to your request. We may require you to provide information sufficient enough to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative. We may limit our response to your exercise of the above rights as permitted under applicable law.

12.7 Agent Authorization and Disability Access

You may designate an authorized agent to make a request on your behalf. As permitted by law, we may require additional verification in response to a request even if you choose to use an agent. You may also make a verifiable consumer request on behalf of your minor child.

To access this Privacy Policy by an alternative method, please contact us at support@edgilearning.com.

12.8 Right to Opt Out and Right to Opt In

Please note we do not sell Personal Information of California Consumers regardless of your age. If you are 16 years of age or older, you have the right to direct us to not sell your Personal Information at any time (the “right to opt out”). We do not sell the Personal Information of consumers we know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt in to Personal Information sales may opt out of future sales at any time.

12.9 Responding to Requests

We will confirm receipt of your request within 10 days from receipt, and provide information about how we will process the request, our verification process, and when you can anticipate a response to the request. We will use commercially reasonable efforts to honor your request within 45 days from receipt. If additional time is needed, we will notify you of the same, along with an explanation and anticipated timeline for the extension which shall not exceed 90 days from the date of receipt.

13. Other California Privacy Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Data which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to: support@edgilearning.com.

14. Location of the Website and Service

14.1 This Website and Service is hosted and operated in the United States. Those who access or use the Website from jurisdictions outside the United States do so at their own choice and risk and are solely responsible for compliance with local law. If you are not a resident of the United States, you acknowledge and agree that we may collect and use your personal information outside your home jurisdiction and that we may store your personal information in the United States or elsewhere.

15. Queries and complaints 

15.1 If you have any questions or wish to exercise any of your rights please contact us by email at support@edgilearning.com or write to Joshua Shapiro at 180 Elm Street, Suite I #184, Pittsfield, Massachusetts 01201.