Last updated: 2020-09-12
EDUGION, INC. ("EDUGION," "we," "us," or "our") operates the website, www.edugion.com ("Site"), and provides products and
services through mobile and other applications ("Services").
why we collect it, how we use the information we collect, and the choices you have to access and update that information.
Please familiarize yourself with our practices and let us know if you have any questions. By using our Site and Services,
you expressly consent to our collection, use, disclosure, and retention of your personal information as described in this
Data Controller and Contracting Parties
For the purposes of the General Data Protection Regulation 2016/679 ("GDPR"), the Data Controller is Edugion, Inc., registered in the State of , Country, with a registered address of 123
Main Street, City, State.
You can contact our Data Protection Officer by sending an email to: email@example.com or by writing
Attn: Legal Department
123 Main Street
- Personal Information that You Provide to Us. Personal information is information that can be used to identify, locate, or contact an
individual, and includes other information that may be associated with an individual. When you interact with our Site and Services, we may collect the following personal
information directly from you:
- "Account or Registration Information" where needed to use our Site and Services, and may include
your name, address, email address, telephone number, birthday, User account name, and password;
- "Contact Information" which generally includes your name, addresses, email addresses, social media website user account
names, and/or telephone numbers;
- "Payment Information" where needed to process payments and generally includes your credit or debit card
number, expiration date, and card verification number;
- "Personal Profile or Service Information" which may include areas of interest, information from social media
interactions, preferences, physical characteristics, photographs and, biographical, health information and/or demographic information;
- "Transaction Information" which may include information about how you interact with and use our Site and Services,
email, other communications, and applications, and how you interact with merchants, business partners, and service providers;
- "Geographic Location Information" but only if your device transmits location data and/or your IP address and you have
activated a location-enabled site or service;
- "Job-Search-Related Information" where needed for recruitment purposes and may include educational and employment
background, driver's license number, and social security number;
- "Survey Data" where needed for the functionality of certain Services and generally includes survey questions and
responses, and may allow you to import email addresses and names in order to send surveys or to allow us to send surveys on your behalf;
- "Access to Your Data" but only if you use certain Services, interactive tools, or authorize us to retrieve information
from another database, User, or other third-party on your behalf; and
- "Your Submissions" which generally includes information you voluntarily provide through free form text boxes, forums,
document upload, or data retrieval or import.
In each of the above instances, you shall know what personal information we collect through our Site and Services because you voluntarily and directly provide it
- Other Information We Automatically Collect through Cookies & Other Technologies. We or our third-party service providers may
collect and store certain technical information when you use our Site and Services. For example, our servers receive and automatically collect information about your computer and
browser, including, for instance, your IP address, browser type, domain name from which you accessed the Site or Services, device size and other software or hardware information.
If you access our Site and Services from a mobile or other device, we may collect a unique device identifier assigned to that device (UDID), type of device, general GPS location,
or other transactional information for that device in order to serve content to it and to improve your experience in using the Site or Services. In addition, we or our third-party
service providers may collect information about how you use of our Site, including but not limited to, the date and time you visit the Site, the areas or pages of the Site that you
visit, the amount of time you spend viewing the Site, the number of times you return to the Site, visits to websites outside our network, preferred language, and other click-stream
pixels, beacons, mobile application identifiers, and Adobe Flash technology) to help us recognize you across the Site and Services, improve your experience, increase security,
measure use and effectiveness of our Services, and serve advertising. You can control cookies through your browser settings and other tools. For more information about our use
- Do Not Track. You can opt-out of being targeted by certain third-party advertising companies online at: Network Advertising Initiative
(www.networkadvertising.org/managing/opt_out.asp) and/or Digital Advertising Alliance (www.aboutads.info/choices/). We currently do not respond to "Do Not Track" browser signals.
Accordingly, your navigation on our Site and Services may be tracked as part of our efforts to gather User information described above. If you arrive at our Site and Services
by way of a link from a third-party site that does respond to "Do Not Track" browser signals, such "Do Not Track" browser signal recognition will end as
soon as you reach our Site and Services.
- Our Legal Bases for Processing. We will only collect and process personal information, including sharing it with third-parties, where
we have a legal basis for such collection and processing. We rely on a number of legal bases, including:
- our legitimate interests in providing and improving our Site and Services;
- our legitimate interests in keeping our Site and Services safe and secure;
- our third-party service providers' legitimate interests as described in "Other Information We Automatically Collect Through Cookies &
Other Technologies" above;
- your consent to the processing of your personal information, which you can revoke at any time;
- where the processing of personal information is necessary for the performance of a contract to which you are a party to, such as our Terms of
- where the processing of your personal information is required to protect your vital interests or those of another person, such as other Users of
our Site and Services; and
- where the processing of personal information is necessary to comply with a legal obligation such as a law, regulation, search warrant, subpoena, or
- How We Use Personal Information.
- Personal Information that You Provide to Us. We may use the personal information that you provide in one or more of the following
- to carry out our obligations arising from your purchase of, or subscription to, our Services or any other contract entered into between you and
- to enable site features such as geographically specific logging, and retrieving and providing analysis of data;
- to send you important notices, such as communications about changes to your account, and our Site and Services terms, conditions, or policies;
- to process payments and to send you emails, invoices, receipts, notices of delinquency, alerting you if we need different or updated payment card
information or other communications in connection with processing and collecting payments;
- to solicit input and feedback to improve our Site and Services and customize your User experience;
- to enable you to communicate with other site or service Users via private messaging or other service specific communication channels;
- to contact you via email, telephone, text or chat in a manner required by law;
- to meet contractual obligations;
- to send you reminders, technical notices, updates, security alerts, support and administrative messages, and service bulletins;
- to inform you about new products or promotional offers, or other opportunities which we feel will be of interest to you, and to provide advertisements
to you through our Site, email messages, text messages, applications, or other methods of communication;
- to manage our Site and Services administration, forum management, or fulfillment;
- to provide customer service and technical support;
- to administer surveys, sweepstakes, giveaways, contests, or similar promotions or events sponsored by us or our partners;
- for internal purposes such as auditing, data analysis, and research to improve our products, Services, and communications;
- to allow you sign-up for special offers from third-parties through our Site and Services; and
- to run (or authorize third-parties to run) statistical research on individual or aggregate trends.
In addition to the uses described above, we may use personal information that we collect for other purposes that are disclosed to you at the time we collect the
information, or with your consent.
- Other Information We Automatically Collect Through Cookies and Other Technologies. We may use information collected from you
through cookies and other tracking technologies in one or more of the following ways:
- to remember you when you return to our Site;
- to understand and analyze trends, to monitor usage, and learn about User behavior;
- to gather demographic information about our User base as a whole;
- to customize ads, content, or offers on our Site and Services; and
- to conduct market research and measurement in order to improve our Site, content, and Services and to make our Site, content, and Services more useful for
- Sharing Personal & Non-Personal Information. We may share your personal information with third parties in the following
- when we engage third-parties to perform services on our behalf, such services include maintenance, hosting, data storage, security, analytics and
data analysis, payment processing, marketing, email and text message distribution, customer service, and surveys and sweepstakes;
- when you communicate with us by email, submit an online form through our Site and Services, purchase a product or service, or otherwise submit a
request through our Site and Services, the personal information you provide may be shared with third-parties to process or respond to your request, provide you with the
products or services you requested, or complete a transaction;
- where necessary to operate our Site and Services, your personal information and the contents of all of your online communications on or through our
Site and Services may be accessed and monitored:
- to satisfy any applicable laws or regulations;
- to defend ourselves in litigation or a regulatory action;
- when we have a good faith belief that we are required to disclose the information in response to legal process (for example, a subpoena,
court order, or search warrant); and
- where we believe our Site and Services are being used in the commission of a crime, including to report such criminal activity or to
exchange information with other companies and organizations for the purposes of fraud protection and risk management, and
- when we have a good faith belief that there is an emergency that poses a threat to the health and/or safety of you, another person, or the
- in the event of a merger, acquisition, debt financing, restructure, sale of EDUGION's assets by or with another company, or a similar corporate
transaction, we may need to disclose and transfer all information about you, including personal information, to the successor company;
- we may share information about you with EDUGION's subsidiaries and affiliates and companies acquired by or merged with EDUGION and its
affiliates, including without limitation, to enable such acquired or merged companies to advertise products and services in which you may be interested; and
- when you register to use a service co-branded by EDUGION and other companies with which we partner, we may share the personal information you
We may share personal information about you for any other purpose(s) disclosed to you at the time we collect your information or with your
consent. Non-personal information may be shared with our partners who referred you to our Site and who may use the data for their market research and measurement purpose. User
information may also be shared with our partners who help us deliver ads to you on a third-party website not controlled by us; for instance, when we put a pixel on a conversion page on
our Site and a marketing partner uses that pixel to optimize the traffic that they send to us.
- User Generated Content, Online Communities and Forums, Profiles, Surveys, Reviews and Ratings. You may choose to publicly disclose
personal information about yourself and others in the course of: (a) contributing User generated content (for instance articles, blogs, surveys, reviews, ratings, or podcasts); (b)
communicating with others in our online forums, communities, or chat rooms; (c) creating User profiles for public view; or (d) posting images, photos, or videos. Be aware,
information that you voluntarily disclose in any of these areas of our Site or Services is unencrypted, public information and, therefore, there can be no expectation of privacy or
and if anonymity is an option). Any personal information you submit in the course of interacting in these public activities can be read, collected, or used by other Users.
public in any of these areas and strongly recommend against sharing any personal or other sensitive information that could directly or indirectly be traced to any individual,
- Accessing & Updating Personal Information. We encourage you to keep your personal information up-to-date and accurate on the
Site. You have several choices; for instance:
- to view and change the personal information that you directly provided to us, you can return to the web page on our Site where you originally
submitted the data and follow the instructions on that web page;
- to correct or update your account information, you can log into our Site where you are registered and navigate to your account;
- to close your account, you can log into the Site and navigate to your account; or
- to change your email preferences, you can visit the email preferences page for the relevant site or follow the opt-out or unsubscribe instructions
included in each email (for more information about email preferences, please see "Email & Other Communications" below).
You can also manage certain aspects of information collection and use, including disabling geo-location, by going to the settings of your mobile device and
reviewing the permissions of each application.
If you have questions about your options, please contact us at: firstname.lastname@example.org. Protecting your privacy
and security is important and we also take reasonable steps to verify your identity before granting access to your data. Please be aware that certain records and information will be
User generated content on our Site, we may not be able to delete it. Further, we take no responsibility for removing or editing any of your public activities or any submissions or
content that is a result of your public activities. We may reject requests that are unreasonably repetitive or impractical, require disproportionate technical effort, or risk the
privacy of others.
- Storing Personal Information. We retain your personal information while your account is active or as needed to provide you Services.
Additionally, we may retain personal information even after your account has been closed if retention is reasonably necessary to comply with our legal or regulatory obligations,
your personal information.
- Email & Other Communications. Our Site and Services may allow us or other Users to communicate with you or other Users through our
in-product instant messaging Services, service-branded emails, SMS, and other electronic communication channels.
- Text Messaging. We may make available text messaging Services in which you can receive messages from us and send messages to us
on your mobile phone.
- Opting Out of Requested Communications. Requested communications include, for instance, email newsletters and software updates
that may be expressly requested by you or which you consented to receive. After you request such communications, you may "opt-out" of receiving them by using one of
the following methods:
- selecting the email "opt-out" or "unsubscribe" link, or following the opt-out instructions included in each email
- returning to the web page where you originally registered your preferences and following the opt-out instructions; or
- contacting us by email at: email@example.com or visit this web form [Hyperlink].
- Opting Out of Transactional or Relationship Communications. Communications that are sent by or on behalf of a User are indicated as
being from that User. Communications that are sent by us are indicated as being from us or one of our account or support specialists. Either type of communication may be
"real time" communications or communications triggered automatically upon the occurrence of certain events or dates, such as appointment reminders. Email
communications received from Users and our administrative announcements are often transactional or relationship messages, such as appointment requests, reminders, and
cancellations. You may not be able to opt-out of receiving certain email messages, although our Services may provide a means to modify the frequency of receiving them.
- Opting Out of General or Promotional Communications. General communications provide information about products, Services, and/or
support and may include special offers, new product information, or invitations to participate in market research. You may opt-out of receiving these general communications by
using one of the following methods:
- selecting the email "opt-out" or "unsubscribe" link, or following the opt-out instructions included in each email communication;
- contacting us by email at: firstname.lastname@example.org.
- Protecting Personal Information. To prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of the information
we collect, we deploy a wide range of technical, physical, and administrative safeguards, including: Transport Layer Security (TLS), firewalls, system alerts, and other information
system security technologies; housing health data in secure facilities that restrict physical and network access; and regular evaluation and enhancement of our information
technology systems, facilities, and information collection, storage, and processing practices. We use reasonable and appropriate administrative, physical, technical, and data
security procedures and controls to safeguard your personal information against unauthorized access, disclosure, loss, misuse, and alteration.
We use third-party service providers to manage credit card and payment processing. These service providers are not permitted to store, retain, or use billing
information except for the sole purpose of credit card and payment processing on our behalf. When you enter payment information to be processed by our third-party service providers, we
encrypt the transmission of that information using TLS technology and do not store it on our systems.
It is important to remember, however, that no system can guarantee 100% security at all times. Accordingly, we cannot guarantee the security of information
stored on or transmitted to or from our Services. We cannot assume responsibility or liability for unauthorized access to our servers and systems. When disclosing any personal
information, you should remain mindful of the fact that it is potentially accessible to the public and, consequently, can be collected and used by others without your consent.
Accordingly, you should carefully consider if you want to submit sensitive information that you would not want disclosed to the public and should recognize that your use of the
Internet and our Site and Services is solely at your risk. You are ultimately responsible for maintaining the secrecy for all your personal information. We have no responsibility or
liability to anyone for the security of your personal information transmitted via the Internet.
- Linked Websites & Services. Our Site and Services may link to other websites or services operated by our affiliates or third parties,
and may carry advertisements or offer content, functionality, newsletters, contests or sweepstakes, or applications developed and maintained by third-parties. We do not exercise
control over third-party website or services. We are not responsible for the privacy practices of any such third-parties. Once you leave our Site or Services via a link, enable a
present a banner ad or other type of advertisement is not an endorsement, authorization, or representation of our affiliation with that third-party nor is it an endorsement of
their privacy or information security policies or practices.
We may also provide social media features on our Site and Services that enable you to share personal information with your social network(s) and to interact with
our Site and Services. Depending on the features, your use of these features may result in the collection or sharing of personal information about you. We encourage you to review the
privacy policies and settings on the social media site(s) with which you interact.
- Privacy of Minors. Our Site and Services requires Users to be at least 18 years of age. Minors and children under the age of 13 are
not permitted to use our Site and Services. We do not knowingly collect personal information from minors or children under the age of 13 or utilize plug-ins or ad networks that
collect personal information through child-directed third-party website or online services. If we learn that we have collected personal information from a minor under 13, we shall
take steps to promptly delete such information.
- International Users. We are headquartered in the United States. Our Site and
Services are intended for Users in the United States and hosted and administrated in the United States or hosted with cloud service providers who are
headquartered in the United States and in other countries. If you are located outside the United States, be aware that information you provide to us or that
we obtain as a result of your use of our Site and Services may be processed in, transferred to, and stored in the United States and in any other countries from where our cloud service providers operate. Please be aware that the privacy laws and standards in certain countries may differ from
those that apply in the country in which you reside. By using our Site and Services or providing us with your information, you consent to the transfer of your information for
processing and storage to the United States and any other country from where our cloud service providers operate.
- California Privacy Rights. This section is provided pursuant to the California Consumer Privacy Act of 2018 (the
"CCPA") and other applicable California Privacy laws. This Section 14 applies solely to our Users who are California residents as defined under
applicable California Privacy laws.
- Information We Collect. Within the last twelve (12) months, we have or may have collected the following categories of information
from our Users and/or consumers:
- identifiers, such as a name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, Social
Security number, driver's license number, or other similar identifiers;
- personal information listed under Cal. Civ. Code § 1798.80(e);
- characteristics of protected classifications under California or federal law;
- commercial information, such as records of personal property, products or Services purchased, obtained, or considered, or other purchasing or consuming
histories or tendencies;
- biometric information;
- internet or other similar network activity, such as browsing history, search history, information regarding your interaction with a website,
application, or advertisement;
- geolocation data;
- professional or employment-related information; and
- inferences drawn from any of the information identified in this section to create a profile about Users reflecting User preferences, characteristics,
psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
- Categories of Sources from Which Information is Collected. We obtain the categories of personal information listed above from the
following categories of sources:
- directly from Users, such as you, as described above under "Personal Information that You Provide to Us";
- indirectly from other Users of our Site and Services;
- indirectly from third-parties that interact with us in connection with the Services that we perform; and
- directly and indirectly through cookies and other technologies, as described above under "Other Information We Automatically Collect Through
- Using and Sharing of Personal Information. The personal information described in the categories above may be used for the
business purposes listed above under “How We Use Personal Information.” We disclose your personal information for a business purpose to the
following categories of third parties: (a) service providers and (b) third parties to whom you authorize or direct us to disclose your personal information in connection with
our Site and Services. In the preceding twelve (12) months, we have disclosed the personal information described in the categories above for the business purposes listed above
under “Sharing Personal and Non-Personal Information.” We also may share personal information about you for any other purpose(s) disclosed to you at the time we
collect your information or with your consent.
- Personal Information “Sold” to Third Parties. We may share information that we have about you, such as a cookie ID or
IP address, with third-party marketing partners who may use this information, on our behalf, to help us deliver advertising on our Site as well as on third-party websites. In
the preceding twelve (12) months, we have made available personal information included in the categories described above to third-parties, including our third-party marketing
We do not sell the personal information of consumers that we know are minors under 16 years of age without affirmative authorization as required under the
- Your Access and Deletion Rights under the CCPA. As of January 1, 2020, California residents, as defined under applicable
California Privacy laws, may take advantage of the following rights:
- You may request, up to two (2) times each year, that we disclose to you, once we receive and confirm your verifiable consumer request, the: (i)
categories and specific pieces of personal information that we have collected about you; (ii) categories of sources from which your personal information is collected; (iii)
business or commercial purpose for collecting your personal information; (iv) categories of personal information that we disclosed for a business purpose; (v) categories of
personal information that we sold about you; (vi) categories of third-parties with whom we have shared your personal information; and (vii) business or commercial purpose
for selling your personal information.
- Subject to certain exceptions and up to two (2) times each year, you may request that we delete any of your personal information that we collected
from you. Once we receive and confirmed your verifiable consumer request for deletion, we will delete (and direct our service providers to delete) such personal information
from our records, unless an exception applies.
- Exercising Your Access and Deletion Rights under the CCPA. To exercise the access and deletion rights described above, please
submit a request to us by sending an email to: email@example.com (with subject line "California Privacy Rights").
You will be asked to provide certain identifying information, such as your name, email, and residency. You will also be asked to validate your request by
clicking a validation link in an email that will be sent to the email address you provided. While processing your request, we may ask you to provide further verifying documentation,
such as proof of residency and identity. We will only use personal information provided in a request to verify the requestor's identity or authority to make the request.
Your request must: (a) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or that
you have authority to make the request; and (b) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related
to your personal information. You may also make a verifiable consumer request on behalf of your minor child. If you are making a request through an authorized agent acting on your
behalf, such authorized agent must provide proof of written authorization to do so, and you must verify your identity directly with us, unless such authorized agent provides proof of a
power of attorney pursuant to Probate Code sections 4000 to 4465.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the
personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the
- Opting-out of the Sales of your Personal Information. Subject to certain exclusions under the CCPA, you have the right to opt-out
of the sale of your personal information. Once we receive your request, we shall not sell your personal information, unless an exclusion applies. To
information that we collected directly from you or other third-parties, please submit a request to us by sending an email to: firstname.lastname@example.org
(with subject line "Opt-Out"). We may deny your request to opt-out if we have a good-faith, reasonable, and documented
belief that the request is fraudulent.
- Non-Discrimination. We shall not discriminate against you for exercising any of your rights under the CCPA. Accordingly, and
unless permitted by the CCPA, we shall not:
- deny you goods or services;
- charge you different prices or rates for goods or services, including through the use of discounts or by imposing penalties;
- provide you a different level or quality of goods or services; or
- suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
We may charge a different price or rate or provide a different level of service if the difference is reasonably related to the value provided by your personal
- Other Applicable California Privacy Laws. Section 1798.83 of the California Civil Code requires select businesses to disclose
policies relating to the sharing of certain categories of your personal information with third parties. If you reside in California and you have provided us with your personal
information, you may request information about our disclosures of certain categories of your personal information to third-parties for direct marketing purposes. To make such a
request, please send us an email at: email@example.com (with subject line "California Privacy Rights") and allow
30 days for a response. We shall not accept requests via the telephone or mail and we are not responsible for notices that are not labeled or sent properly, or that do not have
In accordance with Section 22581 of the California Business and Professions Code if you are a California resident under the age of 18, you may request and obtain
the removal of content or information you have publicly posted. To make such a request, please send us an email at: firstname.lastname@example.org (with subject line
"California Privacy Rights"). Please identify the Site and specific Services to which your removal request relates, including any URLs where the
content or information is posted, and the specific content or information you posted for which you are requesting removal. Please be aware that such a request does not ensure complete
or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.
- Nevada Privacy Rights. FOR RESIDENTS OF NEVADA ONLY. In accordance with SB 220, Nevada consumers may opt-out of the sale of their personal
information to third-parties. If you reside in Nevada and you have provided us with your personal information, you may choose to opt-out of the sale of such personal information by
emailing us at: email@example.com (with subject line "Nevada Privacy Rights"). We may request for additional
information from you in order to verify your identity and/or the authenticity of your request.
- EU Privacy Rights. FOR RESIDENTS OF THE EUROPEAN UNION ONLY. Under European data protection law, in certain circumstances, you have the
- request access to your personal information;
- request correction of your personal information;
- request erasure of your personal information;
- object to processing of your personal information;
- request restriction of processing your personal information;
- request transfer of your personal information; and
- withdraw your consent.
In addition, you have the right to ask us not to process your personal information for marketing purposes. We will usually inform you (before collecting your
personal information) if we intend to use your personal information for such purposes or if we intend to disclose your information to any third party for such purposes.
You can exercise any of these rights by contacting us at: firstname.lastname@example.org (with subject line "EU Privacy
to an EU Data Protection Authority.
which you have a question or concern and how we can contact you.
and modify the "Last Updated" date. If our information practices change in a significant way, you will be provided notice by means of notice on our Site or otherwise in
Services. Your use of our Site and Services following any such change constitutes your agreement that all information collected from or about you through our Site and Services
Last Updated: June , 2020