Privacy Policy | Carnegie Learning

This Privacy Policy applies to any websites, software, applications, or interactive features or online services, owned and operated by CL Zorbit’s Inc., dba Carnegie Learning Canada (hereinafter “CL Zorbit’s,” “we” or “us”) that post a link to or include this Privacy Policy, including the learning platforms we provide access to through separate licensing agreements (“Learning Platforms”) (collectively, our “Sites”). This Privacy Policy also applies to any data we collect offline in connection with use of the Sites.

Please read this Privacy Policy carefully. Please review our Terms of Use, which also applies to your use of the Sites. By accessing, visiting, using, interacting, or submitting information to the Sites, you agree to the practices described in this Privacy Policy.

Note that this privacy policy applies to visitors to our Sites (“Visitors”), which may include teachers, or representatives of schools, learning institutions, school districts, provincial, state or local boards of education or other sponsoring organizations (“Schools”) and parents or legal guardians that utilize our Learning Sites. Our Sites are targeted to a general audience and not intended for use by children younger than 13 (“Children” and each, a “Child”). However, our Learning Sites may be used by students authorized and instructed to access and use our Learning Sites by their School or parent or legal guardian, including Children, for whom we have certain more restrictive practices. To understand our privacy practices with regard to student users, including Children younger than age 13, please review our Student Privacy Policy.

By directing your students to our Learning Sites, you consent on their behalf to our collection, use, and sharing of their information in accordance with this Student Privacy Policy. To the extent there is any conflict between our general privacy practices and our privacy practices with regard to Children, the Student Privacy Policy controls.

When we provide access to the Learning Sites through a School agreement, we collect, process, disclose, and store information on behalf of Schools and only in the ways permitted by the applicable School agreement and applicable law.

CL Zorbit’s collects data about you directly through our Sites, automatically when you visit the Sites, and sometimes from third parties. Some of this data may be considered “personal information” or “personal data,” some of which may be considered “sensitive”, under various applicable laws. We consider data that identifies you as a specific, identified individual (such as your name and email address) to be personal data. We will also treat additional information, including IP addresses and cookie identifiers, as “personal information” “or personal data” where required by applicable law. Note that we may de-identify or pseudonymize personal data so that it is non-personal, such as aggregating or converting it to a code, sometimes using a function commonly known as “hash”. We maintain and use de-identified data without attempting to re-identify it, except where permitted by applicable law, such as to determine whether our de-identification processes satisfy legal requirements. We will treat de-identified and pseudonymized data as non-personal to the fullest extent allowed by applicable law. If we combine non-personal data with personal data, then we will treat the combined information as personal data under this Privacy Policy. The following chart sets out by category the personal data collected (“Category”), the purposes for which the information is collected (“A. Purposes”), the categories of third parties to whom the information may be disclosed for a business purpose (“B. Disclosed To”), and the categories of third parties to whom the information may be sold for monetary value or other valuable consideration or shared for cross contextual behavioral advertising/targeted marketing (“C. Sold/Shared To”). For more information about certain practices disclosed in the chart, please also see the “Additional Details About our Data Practices”.

Category of Data

A. Purpose for Collection;

B. Categories of Third Parties the Data is Disclosed To;

C. Third Parties to whom the Data is Sold/Shared for Targeted Advertising.

Contact Information (such as your name, phone number, email address, mailing address)

A. Purposes for Collection:

(1) Provide You Services (to allow you to participate in the Sites and Learning Platforms, such as to provide information you have requested, including quotes or offers about our products, and provide services in accordance with our agreements with Schools or as authorized by a parent or legal guardian, including to process registration (including verifying information you provide is active and valid) and to provide customer service; to send a confirmation notice of the registration; to analyze and provide academic and learning outcomes based on students’ use of the services); (2) Advertising Activities and Marketing Messages (to provide information and promotional materials about the products and services we offer (CL Zorbit’s will never send you unsolicited third-party promotional emails); (3) Personalization (to tailor the content and advertising we display to you or others, on the Sites or elsewhere, as well as communications we send to you, and to analyze trends and statistics regarding use of the Sites); (4) Administrative (to verify your identity; recognize you across devices; to administer and manage accounts, including password resetting, responding to questions raised, to contact you about any problems with your account or conduct on the Site; to contact you with regard to your use of the Sites or similar administrative communications, including changes to the policies governing the Sites; (5) Internal Business Purposes (to analyze the performance and functioning of the Sites, including to test, correct and improve our content, applications and services; to develop new applications, products and services; to research how users interact with the Sites, conduct surveys, and to perform other market research; to manage CL Zorbit’s’ everyday business needs, such as administration and improvement of our Sites and related services; for external academic research and scholarship); (6) Security (to investigate, detect, prevent, and protect against misuse of our systems, fraud, crime or otherwise illegal activities, or activities that violate our policies); (7) Legal (to comply with the law; resolve disputes; enforce our agreements and policies; comply with our contractual obligations; cooperate in governmental or other legal inquiries; fulfill regulatory reporting obligations; protect our or others’ rights or assets); (8) Business Transitions (in connection with a merger, acquisition, consolidation, bankruptcy, or other corporate transition, affecting all or part of our assets, including during due diligence); (9) Other Purposes as Disclosed at the time of collection/with your consent

B. Categories of Third Parties Data Is Disclosed to:

(1) Advertising and Analytics Partners (such as analytics companies, third party advertisers, and marketing agencies, including those who assist us with surveys and market or product research and development); (2) Schools and School Affiliated Third Parties;(3) Parent and Affiliated Companies; (4) Social Media and Other Third Party Platforms; (5) Sweepstakes/Contest/Promotion Partners; (7) Order Fulfillment Vendors (such as payment processors; delivery services); (8) Technology Systems Service Providers (such as webhosts, database hosts, cloud computing providers, and technology maintenance and repair vendors); (9) Communications Services Providers (such as email delivery vendors and text messaging service providers); (10) Security Vendors; (11) Government Agencies and Law Enforcement or Where Required by Law (including third parties in connection with court or other legal proceedings); (12) Third parties in connection with business transitions; (13) Third parties to whom you agree or direct us to share your information; (14) Other service providers who solely use your data to provide services to us or to you

C. Categories of Third Parties Data is Sold/Shared for Targeted Advertising to:

Third Party Advertising and Analytics Companies;

This category of data is not sold or shared for targeted advertising.

Payment and Financial Information (such as credit or debit card number, expiration date, billing address, or other payment card data)

A. Purposes for Collection:

(1) Provide You Services (to allow you to participate in the Sites and Learning Platforms, such as to provide services in accordance with our agreements with Schools or as authorized by a parent or legal guardian, including to process your purchase of our Learning Platform tools); (2) Administrative (to recognize you across devices; to administer and manage accounts); (3) Internal Business Purposes (to manage CL Zorbit’s’ everyday business needs, such as administration and improvement of our Sites and related services); (4) Security (to investigate, detect, prevent, and protect against misuse of our systems, fraud, crime or otherwise illegal activities, or activities that violate our policies); (5) Legal (to comply with the law; resolve disputes; enforce our agreements and policies; comply with our contractual obligations; cooperate in governmental or other legal inquiries; fulfill regulatory reporting obligations; protect our or others’ rights or assets); (6) Business Transitions (in connection with a merger, acquisition, consolidation, bankruptcy, or other corporate transition, affecting all or part of our assets, including during due diligence); (7) Other Purposes as Disclosed at the time of collection/with your consent

B. Categories of Third Parties Data Is Disclosed to:

(1) Affiliated Companies; (2) Order Fulfillment Vendors (such as payment processors; delivery services); (3) Technology Systems Service Providers (such as webhosts, database hosts, cloud computing providers, and technology maintenance and repair vendors); (4) Government Agencies and Law Enforcement or Where Required by Law (including third parties in connection with court or other legal proceedings); (5) Third parties in connection with business transitions; (6) Third parties to whom you agree or direct us to share your information; (7) Other service providers who solely use your data to provide services to us or to you

C. Categories of Third Parties Data is Sold/Shared for Targeted Advertising to:

This category of data is not sold or shared for targeted advertising.

Transaction Information (such as data about the suite of learning tools you purchase, customer service contacts, and sweepstakes or contest participation)

A. Purposes for Collection:

(1) Provide You Services (to allow you to participate in the Sites and Learning Platforms, such as to provide services in accordance with our agreements with Schools or as authorized by a parent or legal guardian, including to process your purchase of our Learning Platform tools); (2) Administrative (to recognize you across devices; to administer and manage accounts); (3) Internal Business Purposes (to manage CL Zorbit’s’ everyday business needs, such as administration and improvement of our Sites and related services; develop new applications, products, and services; analyze academic and learning outcomes and preferences; for external academic research and scholarship); (4) Security (to investigate, detect, prevent, and protect against misuse of our systems, fraud, crime or otherwise illegal activities, or activities that violate our policies); (5) Legal (to comply with the law; resolve disputes; enforce our agreements and policies; comply with our contractual obligations; cooperate in governmental or other legal inquiries; fulfill regulatory reporting obligations; protect our or others’ rights or assets); (6) Business Transitions (in connection with a merger, acquisition, consolidation, bankruptcy, or other corporate transition, affecting all or part of our assets, including during due diligence); (7) Other Purposes as Disclosed at the time of collection/with your consent

B. Categories of Third Parties Data Is Disclosed to:

(1) Parent and Affiliated Companies; (2) Order Fulfillment Vendors (such as payment processors; delivery services); (3) Technology Systems Service Providers (such as webhosts, database hosts, cloud computing providers, and technology maintenance and repair vendors); (4) Security Vendors; (5) Government Agencies and Law Enforcement/Where Required by Law (including third parties in connection with court or other legal proceedings); (6) Third parties in connection with business transitions; (7) Third parties to whom you agree or direct us to share your information; (8) Other service providers who solely use your data to provide services to us or to you

C. Categories of Third Parties Data is Sold/Shared for Targeted Advertising to:

This category of data is not sold or shared for targeted advertising.

User Account Information (such as username, password, communication preferences, and account settings)

A. Purposes for Collection:

(1) Provide You Services (to allow you to participate in the Sites and Learning Platforms and provide services in accordance with our agreements with Schools or as authorized by a parent or legal guardian, including to process registration (including verifying information you provide is active and valid) and to provide customer service); (3) Personalization (to tailor the content and advertising we display to you or others, on the Sites or elsewhere, as well as communications we send to you, and to analyze trends and statistics regarding use of the Sites); (4) Administrative (to verify your identity; recognize you across devices; to administer and manage accounts, including password resetting); (5) Internal Business Purposes (to analyze the performance and functioning of the Sites, including to test, correct and improve our content, applications and services; to manage CL Zorbit’s’ everyday business needs, such as administration and improvement of our Sites and related services; (6) Security (to investigate, detect, prevent, and protect against misuse of our systems, fraud, crime or otherwise illegal activities, or activities that violate our policies); (7) Legal (to comply with the law; resolve disputes; enforce our agreements and policies; comply with our contractual obligations; cooperate in governmental or other legal inquiries; fulfill regulatory reporting obligations; protect our or others’ rights or assets); (8) Business Transitions (in connection with a merger, acquisition, consolidation, bankruptcy, or other corporate transition, affecting all or part of our assets, including during due diligence); (9) Other Purposes as Disclosed at the time of collection/with your consent.

B. Categories of Third Parties Data Is Disclosed to:

(1) Schools and School Affiliated Third Parties; (2) Parent and Affiliated Companies; (6) Technology Systems Service Providers (such as webhosts, database hosts, cloud computing providers, and technology maintenance and repair vendors); (7) Security Vendors; (8) Communications Services Providers (such as email delivery vendors and text messaging service providers); (9) Government Agencies and Law Enforcement/Where Required by Law (including third parties in connection with court or other legal proceedings); (10) Third parties in connection with business transitions; (11) Third parties to whom you agree or direct us to share your information; (12) Other service providers who solely use your data to provide services to us or to you

C. Categories of Third Parties Data is Sold/Shared for Targeted Advertising to:

This category of data is not sold or shared for targeted advertising.

Educational Information (such as your school, school district, school address, employment information related to your role as administrator or teacher, job title, grade, student roster)

A. Purposes for Collection:

(1) Provide You Services (to allow you to participate in the Sites and Learning Platforms, such as to provide services in accordance with our agreements with Schools or as authorized by a parent or legal guardian, including to process registration and to provide customer service; to analyze and provide academic and learning outcomes based on students’ use of the services); (2) Advertising Activities and Marketing Messages (to provide information and promotional materials about the products and services we offer); (3) Personalization (to tailor the content and advertising we display to you or others, on the Sites or elsewhere, as well as communications we send to you, and to analyze trends and statistics regarding use of the Sites); (4) Administrative (to administer and manage accounts); (5) Internal Business Purposes (to analyze the performance and functioning of the Sites, including to test, correct and improve our content, applications and services; to develop new applications, products and services; to research how users interact with the Sites, conduct surveys, and to perform other market research; to manage CL Zorbit’s’ everyday business needs, such as administration and improvement of our Sites and related services; for external academic research and scholarship); (6) Security (to investigate, detect, prevent, and protect against misuse of our systems, fraud, crime or otherwise illegal activities, or activities that violate our policies); (7) Legal (to comply with the law; resolve disputes; enforce our agreements and policies; comply with our contractual obligations; cooperate in governmental or other legal inquiries; fulfill regulatory reporting obligations; protect our or others’ rights or assets); (8) Business Transitions (in connection with a merger, acquisition, consolidation, bankruptcy, or other corporate transition, affecting all or part of our assets, including during due diligence); (9) Other Purposes as Disclosed at the time of collection/with your consent

B. Categories of Third Parties Data Is Disclosed to:

(1) Schools and School Affiliated Third Parties; (2) Parent and Affiliated Companies; (3) Order Fulfillment Vendors (such as payment processors, delivery services); 4) Technology Systems Service Providers (such as webhosts, database hosts, cloud computing providers, and technology maintenance and repair vendors); (5) Communications Services Providers (such as email delivery vendors and text messaging service providers); (6) Security Vendors; (7) Government Agencies and Law Enforcement/Where Required by Law (including third parties in connection with court or other legal proceedings); (8) Third parties in connection with business transitions; (9) Third parties to whom you agree or direct us to share your information; (10) Other service providers who solely use your data to provide services to us or to you

C. Categories of Third Parties Data is Sold/Shared for Targeted Advertising to:

This category of data is not sold or shared for targeted advertising.

Device ID/Information (IP address, mobile device ID, other unique ID, device Information (device model, operating system version, device date and time, mobile network information)

A. Purposes for Collection:

(1) Provide You Services (to allow you to participate in the Sites and Learning Platforms and to provide customer service); (2) Advertising Activities and Marketing Messages (to provide information and promotional materials about the products and services we offer); (3) Personalization (to tailor the content and advertising we display to you or others, on the Sites or elsewhere, as well as communications we send to you, and to analyze trends and statistics regarding use of the Sites); (4) Administrative (to verify your identity; recognize you across devices); (5) Internal Business Purposes (to analyze the performance and functioning of the Sites, including to test, correct and improve our content, applications and services; to manage CL Zorbit’s’ everyday business needs, such as administration and improvement of our Sites and related services; analyze academic and learning outcomes and preferences; for external academic research and scholarship); (6) Security (to investigate, detect, prevent, and protect against misuse of our systems, fraud, crime or otherwise illegal activities, or activities that violate our policies); (7) Legal (to comply with the law; resolve disputes; enforce our agreements and policies; comply with our contractual obligations; cooperate in governmental or other legal inquiries; fulfill regulatory reporting obligations; protect our or others’ rights or assets); (8) Business Transitions (in connection with a merger, acquisition, consolidation, bankruptcy, or other corporate transition, affecting all or part of our assets, including during due diligence); (9) Other Purposes as Disclosed at the time of collection/with your consent.

B. Categories of Third Parties Data Is Disclosed to:

(1) Advertising and Analytics Partners (such as analytics companies, third party advertisers, and marketing agencies); (2) Schools and School Affiliated Third Parties; (3) Parent Affiliated Companies; (4) Social Media and Other Third Party Platforms; (7) Order Fulfillment Vendors (such as payment processors); (8) Technology Systems Service Providers (such as webhosts, database hosts, cloud computing providers, and technology maintenance and repair vendors); (9) Communications Services Providers (such as email delivery vendors and text messaging service providers); (10) Security Vendors; (11) Government Agencies and Law Enforcement/Where Required by Law (including third parties in connection with court or other legal proceedings); (12) Third parties in connection with business transitions; (13) Third parties to whom you agree or direct us to share your information; (14) Other service providers who solely use your data to provide services to us or to you

C. Categories of Third Parties Data is Sold/Shared for Targeted Advertising to:

Third Party Advertising and Analytics Companies;

Social Media Companies.

Information about Your Interests and Preferences

A. Purposes for Collection:

(1) Advertising Activities and Marketing Messages (to provide information and promotional materials about the products and services we offer); (2) Personalization (to tailor the content and advertising we display to you or others, on the Sites or elsewhere, as well as communications we send to you, and to analyze trends and statistics regarding use of the Sites); (3) Internal Business Purposes (to develop new applications, products and services; to research how users interact with the Sites, conduct surveys, and to perform other market research; to manage CL Zorbit’s’ everyday business needs, such as administration and improvement of our Sites and related services; for external academic research and scholarship; analyze academic and learning outcomes and preferences; for external academic research and scholarship); (4) Security (to investigate, detect, prevent, and protect against misuse of our systems, fraud, crime or otherwise illegal activities, or activities that violate our policies); (5) Legal (to comply with the law; resolve disputes; enforce our agreements and policies; comply with our contractual obligations; cooperate in governmental or other legal inquiries; fulfill regulatory reporting obligations; protect our or others’ rights or assets); (6) Business Transitions (in connection with a merger, acquisition, consolidation, bankruptcy, or other corporate transition, affecting all or part of our assets, including during due diligence); (7) Other Purposes as Disclosed at the time of collection/with your consent.

B. Categories of Third Parties Data Is Disclosed to:

1) Advertising and Analytics Partners; (2) Schools and School Affiliated Third Parties; (3) Parent Affiliated Companies; (4) Security Vendors; (5) Government Agencies and Law Enforcement/Where Required by Law (including third parties in connection with court or other legal proceedings); (6) Third parties in connection with business transitions; (7) Third parties to whom you agree or direct us to share your information; (8) Other service providers who solely use your data to provide services to us or to you

C. Categories of Third Parties Data is Sold/Shared for Targeted Advertising to:

Third Party Advertising and Analytics Companies.

Demographic Information (such as your age, date of birth, sex and/or gender, level of education)

A. Purposes for Collection:

(1) Provide You Services (to allow you to participate in the Sites and Learning Platforms, such as to provide services in accordance with our agreements with Schools or as authorized by a parent or legal guardian, including to process registration and to provide customer service; to analyze and provide academic and learning outcomes based on students’ use of the services; (2) Internal Business Purposes (to analyze the performance and functioning of the Sites, including to test, correct and improve our content, applications and services; to research how users interact with the Sites, conduct surveys, and to perform other market research; to manage CL Zorbit’s’ everyday business needs, such as administration and improvement of our Sites and related services); (3) Security (to investigate, detect, prevent, and protect against misuse of our systems, fraud, crime or otherwise illegal activities, or activities that violate our policies); (4) Legal (to comply with the law; resolve disputes; enforce our agreements and policies; comply with our contractual obligations; cooperate in governmental or other legal inquiries; fulfill regulatory reporting obligations; protect our or others’ rights or assets); (5) Business Transitions (in connection with a merger, acquisition, consolidation, bankruptcy, or other corporate transition, affecting all or part of our assets, including during due diligence); (6) Other Purposes as Disclosed at the time of collection/with your consent

B. Categories of Third Parties Data Is Disclosed to:

(1) Advertising and Analytics Partners; (2) Schools and School Affiliated Third Parties; (3) Parent Affiliated Companies; ); (4) Technology Systems Service Providers (such as webhosts, database hosts, cloud computing providers, and technology maintenance and repair vendors); (5) Security Vendors; (6) Government Agencies and Law Enforcement/Where Required by Law (including third parties in connection with court or other legal proceedings); (7) Third parties in connection with business transitions; (8) Third parties to whom you agree or direct us to share your information; (9) Other service providers who solely use your data to provide services to us or to you

C. Categories of Third Parties Data is Sold/Shared for Targeted Advertising to:

This category of data is not sold or shared for targeted advertising.

Sensory, Photo/Video Data, and Other User Generated Content (such as audio recordings from Learning Platform trainings)

A. Purposes for Collection:

(1) Provide You Services (to allow you to participate in the Sites and Learning Platforms, such as to provide services in accordance with our agreements with Schools or as authorized by a parent or legal guardian, including to process registration and to provide customer service; to analyze and provide academic and learning outcomes based on students’ use of the services)); (2) Advertising Activities and Marketing Messages (to provide information and promotional materials about the products and services we offer); (3) Internal Business Purposes (to analyze the performance and functioning of the Sites, including to test, correct and improve our content, applications and services; to research how users interact with the Sites, conduct surveys, and to perform other market research; to manage CL Zorbit’s’ everyday business needs, such as administration and improvement of our Sites and related services); (4) Security (to investigate, detect, prevent, and protect against misuse of our systems, fraud, crime or otherwise illegal activities, or activities that violate our policies); (5) Legal (to comply with the law; resolve disputes; enforce our agreements and policies; comply with our contractual obligations; cooperate in governmental or other legal inquiries; fulfill regulatory reporting obligations; protect our or others’ rights or assets); (6) Business Transitions (in connection with a merger, acquisition, consolidation, bankruptcy, or other corporate transition, affecting all or part of our assets, including during due diligence); (7) Other Purposes as Disclosed at the time of collection/with your consent

B. Categories of Third Parties Data Is Disclosed to:

C. Categories of Third Parties Data is Sold/Shared for Targeted Advertising to:

This category of data is not sold or shared for targeted advertising.

We provide in this section additional detail about the information practices listed in the chart above, where it would be helpful for your understanding of such practices.

Device ID/Interaction Information. CL Zorbit’s and our third-party business partners may use a variety of technologies that automatically or passively collect certain information when you visit or interact with our Sites (“Device ID/Interaction Information”). Device ID/Interaction Information may include, but is not limited to:

Your IP address, mobile device identifier and other unique identifier
Device information, including device model, operating system version, device date and time, mobile network information
Approximate location of your device, which may be collected or inferred through other information we collect, such as IP address.
How you use and interact with the Sites, including your search terms, pages you visit, content you view, and your preferences

Many browsers and devices allow you to block the transmission of automatically collected information, such as your IP address, or to block the installation of cookies.

Device ID/Interaction Information may be collected through the use of the following technologies:

Cookies. When you use our Sites, CL Zorbit’s may store data in “cookies” or similar technology on your devices, which are data files placed on your computer or other device when you visit the Sites or otherwise access our online content. We use both session and persistent cookies (which remain on your computer after the browser has been closed). CL Zorbit’s may use cookies for many purposes, including, without limitation, to collect information about how you use our Sites (including to track the pages you’ve visited), to remember you and your settings and your preferences, and to show you personalized content based on information we have collected or inferred about you, such as your school district and your academic interests. This information allows us to customize your CL Zorbit’s experience so that your visit is as relevant and as valuable to you as possible. For more information on cookies, visit www.allaboutcookies.org.

Web Beacons. We may use web beacons (small graphic images or other web programming code, also known as "1x1 GIFs" or "clear GIFs") and similar technologies on our Sites and within our communications to you. Web beacons can recognize certain types of information on your computer such as cookies, the time and date a page is viewed, and a description of the page where the web beacon is placed. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Sites, to monitor how users navigate the Sites, to count how many e-mails that were sent were actually opened or links were actually viewed and to improve your experience on the Sites. Our web beacons may collect some contact information (for example, the email address associated with an email message that contains a web beacon).

Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Sites, such as the links you click on. The code is temporarily downloaded onto your device from our web server or a third -party service provider, is active only while you are connected to the Sites, and is deactivated or deleted thereafter.

Data Collection from Mobile Devices. We use embedded scripts and similar tools to collect information from mobile devices such as the hardware model, operating system and version, identification numbers assigned to your mobile device, such as the ID for Advertising (IDFA) on Apple devices, and the Advertising ID on Android devices, mobile network information, and website usage behavior. In addition, we may use a variety of other technologies that collect similar information for security, fraud detection, and maintenance purposes.

Session Recording Technology. CL Zorbit’s may record through session replay technology your interactions with the Sites, such as what pages you visit on the Sites, how long you visit those pages, and any links you click or information you provide. We use this information for our internal business purposes, such as for website analytics, to improve the Sites and our products and services, and to address functionality issues.

In addition, we may use a variety of other technologies that collect similar device and device interaction information for security, fraud detection, and maintenance purposes.

Data We Receive or Collect from Third Parties

Enhancement Data. We may receive certain data about you from third parties. If you are on another website and agree to receive information from us, that site will forward your information to us so that we may contact you. We may validate or supplement that data with the information we collect with outside records from other third parties, such as public databases, publicly available social media or other web pages, joint marketing partners, and third parties who enhance the data we have about you. We use this data to respond to your requests, tailor content, offer you products or services that we believe may interest you, enhance our products and services, and for other business purposes. The data collected and stored by third parties is subject solely to the third party’s privacy practices.

Invite-a-Colleague Features. You may choose to provide us names or other contact information for a colleague or friend to enable them to create an account with the Sites. If you send a communication through the Sites, the data you provide (names, email addresses, etc.) is to facilitate the communication and is not used for other purposes, unless we obtain consent from that person. If you disclose any personal data relating to other people to us, you represent that you have the authority to do so and to permit us to use the data in accordance with this Privacy Policy.

Information We Receive From Schools and School-Affiliated Third Parties.
If you are affiliated with a School, we may receive information about you from Schools or from third parties as directed by Schools or made available through Schools. For example, your School may provide us your name and email address so that we may contact you, such as to send you information on how to register for an account. We may also receive information from your School to confirm that you are an educator or otherwise eligible to sign-up for an account. We may also collect information when you sign-in to use our Learning Platforms and interact with us directly through a separate third-party platform with whom your School has a relationship.

Your School is responsible for providing you notice of its own privacy policy(ies) that apply to the personal data we collect from or receive about you and your students through the Learning Platforms on behalf of the School. If you have questions on whether any alternative or supplemental terms apply to the collection, use, and sharing of your information, please contact your School. If you want to amend, remove, modify, or access information submitted to us by a School, please contact your School.
Data You Provide Directly. We may ask you to provide data to us when you use the Sites, for example, in the following ways:

Chat Boxes. When you participate in our Chat feature, CL Zorbit’s can record, use, and retain your information provided, as well as the communications within the chat, for purposes of assisting you during the conversation. If you do not consent, please do not continue with chat assistance.

Sweepstakes, Contests, & Promotions. We may offer sweepstakes, contests or other promotions (any, a "Promotion"), that may require registration. By participating in a Promotion, you are agreeing to the provisions, conditions, or official rules that govern that Promotion, which may contain specific requirements of you (including, without limitation and except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing materials). If you choose to enter a Promotion, personal data may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, as required by law or permitted by the Promotion's terms or official rules (such as on a winners list).

Credit card information (Parents only). Parents are required to pay by credit card. This information will be stored within the third-party service we use to process online payments called Stripe.
Disclosure of Data to Third Parties
CL Zorbit’s may share non-personal data, such as aggregate user statistics, de-identified, pseudonymized or hashed data (such as hashed email addresses), and Device ID/Interaction Information, with third parties in our discretion, including for targeted advertising purposes, unless prohibited by applicable law or our agreement with a School. For example, CL Zorbit’s may provide other businesses and members of the public, aggregated statistical data showing general usage patterns and statistics about our Sites, interactions, and transactions, or otherwise share non-personal data in its discretion, including for targeted advertising purposes.

CL Zorbit’s does not share your personal data with unaffiliated third parties for their own direct marketing purposes without your consent. You may withdraw your consent to further data sharing at any time.

Please note that we are not responsible for the privacy practices of any third party. If you decide that you do not want to receive communications from a third party, or have questions about their privacy practices, you will need to contact that third party directly.

Parent, Subsidiaries, and Affiliates. CL Zorbit’s also may share personal or other information with its parent company, subsidiaries and affiliates, primarily for business and operational purposes.

Schools and School-Affiliated Third Parties. As discussed above, we provide the access to our Learning Platforms through agreements with Schools. Accordingly, Schools (and those who obtain authorized access from the Schools, including administrators) have access to all of the data we collect via registration and interactions with the Learning Platforms (including courses and videos viewed or used and how you interact with those courses and videos) by users associated with that School.

A School may also direct us to share data with a third party affiliated with the School. For example, you may be asked to sign-in to our Learning Platforms through a third-party platform with whom your School has a relationship. When you choose to sign-in through a third-party platform, data collected through your use of the Learning Platforms may be shared with those third parties.
We encourage you to read the privacy policies of the Schools and third-party platforms you use that may collect and use your data and the data that we share via registration and interactions with the Learning Platforms, as those parties have their own policies. Please contact us as detailed below if you have questions about which entities may be involved.

Social Media Features and Other Third Party Sites. The Sites may permit you to interact with a third-party platform (such as Google, Facebook, Instagram, LinkedIn, and Pinterest), for example "liking" or "sharing" content from the Sites, posting your social media posts to the Sites, including a hashtag associated with us in your social media post, or creating an account or registering with the Service using existing login information from a third-party platform ("Social Media Features"). Also, both we and the third-party may have access to certain data about you and your use of the Sites and the third-party service. These third-party social networking companies may collect data about your visit to our Sites through the Social Media Features we have integrated into the Service. Note that through the Social Media Features, these third-party social networking companies may be able to collect certain data about your visits to the Sites regardless of whether or not you affirmatively interact with the Social Media Features and whether or not you are logged into (or have) an account with the social networking company.

If you use Social Media Features, your interaction and personal data may be publicly disclosed on the Sites and on the third-party platform. If others give us access to their profile, page, or other content on a third-party platform, we may also receive data about you if it is accessible through that content. Your use of Social Media Features is subject to the Terms of Use for the Sites.

The data we collect in connection with Social Media Features is subject to this Privacy Policy; the data the third-party platform collects is subject to the third-party’s privacy practices (including whether the third-party shares data with us, the types of data shared, and your choices about what is visible to others on the third-party platform).

In addition, the third-party platform service may set their own cookies and collect data about your use of the Sites, including your IP address or other device identifiers, and which pages you visit on the Sites. These third-party platforms may be able to collect certain data on your visits to the Sites regardless of whether or not you affirmatively interact with the feature and whether or not you are logged into (or have) an account with the third-party platform. If you are logged out or do not have an account and visit a page with a social plug-in, your browser sends a more limited set of information. Like other sites, the third-party platform will receive data about the webpage you are visiting, the date and time of your visit, and other browser-related information. They may use that data to help them improve their products or for other purposes set forth in their privacy policy. We may also receive data about you if other users of social media give us access to their profiles and you are one of their connections or "friends."

Companies Providing Services on our Behalf. CL Zorbit’s may share your information with third parties who perform services and functions on our behalf to support our interactions with you including, for example, by fulfilling information requests, administering surveys or contests, providing necessary technical services, or communicating with you. However, all such third parties have no independent rights to your information and are prohibited from using your information in any way that contradicts CL Zorbit’s privacy policy. Our third-party service providers may be located in the U.S., Canada or other foreign jurisdictions.

Disclosures During Business Transfers. CL Zorbit’s may also share personal or other data in the event of an acquisition, reorganization or merger of CL Zorbit’s or its assets, including, without limitation, during the course of any due diligence process, CL Zorbit’s reserves the right to disclose and transfer all data related to the Sites, including personal data. In the event of the acquisition of CL Zorbit’s, you will be sent a notification via the email address you have provided us in accordance with applicable law.

CL Zorbit’s works with third parties, such as analytics companies, network advertisers, ad agencies, and others who provide us with information about the Sites, users, and our advertisements, and who serve our advertisements on our Sites and elsewhere online. We and our third-party business partners collect certain information about your visits to and activity on our Service and other websites and services, and may use this information to target advertising to you and others and to assess the effectiveness of our advertising. We may also share (or permit third parties to collect) certain information, such as Device ID/Information, aggregated or de-identified or pseudonymized or hashed information, with these third parties for similar purposes.

These third parties may set and access their own tracking technologies on your device (including cookies and web beacons) and may otherwise collect or have access to your personal data over time, including your visits to and activity on the Sites as well as other websites and online services, some of which may be personal information or personal data under various state laws.

If you would like to opt-out of third-party advertising and analytics, there are a variety of tools available to you:

Cookie Opt-Out Tools. To disable sharing through cookies set on our site by third parties for advertising and analytics purposes, please adjust your settings by using our Cookie Preference Center. Certain states provide additional rights. Please see our Jurisdiction-Specific Rights section below for more information.
Do Not Track. Do Not Track (“DNT”) signals offered by some web browsers are settings that request that a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug in providers, and/or other web services you encounter while browsing to stop tracking your activity. You can learn more about and set up Do Not Track here.
Global Privacy Controls. Global Privacy Control (“GPC”) is a technical specification in your browser settings that you can use to automatically inform websites of your privacy preferences with regard to third-party online tracking. You can find out more about and set up GPC here.
NAI/DAA Opt-Out. Some of the companies we use may be members of the Network Advertising Initiative (“NAI”) or Digital Advertising Alliance (“DAA”). The NAI provides information regarding targeted advertising and the opt-out procedures of NAI members, including opt-out mechanisms for web browsers, mobile and other connected devices, and a tool to opt out from participating NAI members using your hashed email address for interest-based advertising. You may also want to visit the DAA's website, which provides information regarding targeted advertising and offers an opt-out for DAA-participating companies. To learn more about interest-based advertisements from participating third parties in Canada, please visit the Canadian DAA online choice page at http://youradchoices.ca/choices/.
Google Analytics. We use Google Analytics, which use cookies and similar technologies to collect and analyze information about the use of the Sites and report on activities and trends. This service may also collect information about the use of other websites, apps, and online services. You can learn about Google's practices, and opt out of them by downloading the Google Analytics opt-out browser add-on.

Please note that opting out through these mechanisms does not opt you out of being served advertising, and that you will continue to receive generic ads while online. Your opt-out choices are typically browser and device specific; if you disable your cookies, upgrade your browser after opting out or if you use multiple different devices, please opt-out on each device and each browser separately.

Certain states provide additional rights. Please see Section 11 - Jurisdiction-Specific Rights below for more information.

Marketing Messages from Us. You may opt-out of marketing communications as set forth below.
- Email. You may unsubscribe from marketing emails we send you through the opt-out mechanism included in each such email. Note that we reserve the right to send you certain email or postal communications relating to your use of the Sites, announcements, notices of changes to this Privacy Policy or our other terms, or similar administrative or transactional messages, and these transactional messages may be unaffected if you choose to opt-out from marketing emails.
- Text Messages. If you sign up to receive SMS, MMS or RCS messages from CL Zorbit’s, you may unsubscribe by replying “STOP”.
Access, Correction and Deletion. Members can access, correct, and delete certain information related to your use of our Sites by accessing your CL Zorbit’s account. If you use our Learning Platforms through an agreement with a School and want to amend, remove, modify, or access information not otherwise available through your account, please contact your School. Visitors to the Sites can also ask us to update your information by contacting us at privacy@carnegielearning.com. For users of the Learning Platforms, you may need consent from the applicable School to modify information we hold.

CL Zorbit’s takes commercially reasonable steps to help protect and secure personal data. We have implemented an information security program with numerous measures, including administrative, technical and physical controls that are designed to reasonably safeguard information that can individually identify you against the loss, misuse and alteration of the information under our control. However, please remember that no data storage or data transmission over the Internet, or by other means, can be guaranteed to be 100% secure. Thus, while we strive to protect your personal data, CL Zorbit’s cannot ensure or warrant the security of any information you transmit to us. Therefore, you understand, acknowledge, and agree that you transmit certain personal data to the Sites at your own risk.

The Sites may contain links to other web sites or include other content hosted and served by third parties that CL Zorbit’s does not control. The third parties whose content appears on the Sites may collect information about you through the use of cookies and web beacons, may independently collect or solicit personal data, and may have the ability to track your use of their sites and services. Likewise, our content, including some of our Learning Platforms, may be provided through or be included on third parties’ web pages and web sites that are not associated with CL Zorbit’s and over which we have no control. We may collect Usage Information through CL Zorbit’s content appearing on third party sites. CL Zorbit’s is not responsible for the privacy practices of any third party.

CL Zorbit’s is headquartered in Canada with offices in the United States. For example, CL Zorbit’s parent company, Carnegie Learning, Inc., is headquartered in the United States. If you are a user of the Sites outside of the United States or Canada, by using the Sites and/or providing us with information, you acknowledge and agree that your personal information may be processed for the purposes identified in the Privacy Policy. In addition, we and our Canadian, US and other foreign service providers, may process your personal information in the country in which it was collected and in other countries. Please note that if you are a United States or Canadian resident, your personal information will be stored in Canada and/or the United States. By providing your information, you fully understand and unambiguously consent to this transfer, processing, and storage of your information in the United States, Canada, and other jurisdictions, where laws regarding processing of personal information may be less stringent than the laws in your country, and where governments, courts or law enforcement or regulatory agencies in those other countries may be able to obtain disclosure of that personal information through the laws of those countries.

We retain the personal data that we collect from and about for as long as it is needed to provide access to the Site or to manage the account. We take reasonable steps to delete the personal data we collect if your registration to use our Site lapses and you opt out of receiving further communications from us, or if you ask us to delete your data. We may however retain and use personal data as necessary to comply with our legal and regulatory obligations, to resolve disputes and to enforce our agreements, and we may retain and use anonymous and aggregated information for performance reporting, benchmarking and analytic purposes and for product and service improvement.

We ask that you periodically review our Privacy Policy to be sure you are familiar with the most current version. The Policy will state its effective date, which is the most recent date on which we revised the Policy.

To the extent allowed by applicable law and our agreement with a School, as applicable, CL Zorbit’s reserves the right to make changes to our Privacy Policy at any time. Any changes will be effective upon posting, unless otherwise indicated. Your continued use of the Sites after the effective date of the revised Privacy Policy (or other act as specified in the revised Privacy Policy) will constitute your consent to those changes to the fullest extent allowed by applicable law. If we make material changes to the way we treat personal data we have previously collected about you, we will provide notice through the Sites and may also notify you in other ways, such as by email to your registered email address, in our discretion. However, we will not make material changes to how we treat previously collected personal data without your consent (opt-in or opt-out for adults and prior parental consent for Children), as required by law. You may need to consent to a new Privacy Policy in order to continuing using the Sites.

For any questions about CL Zorbit’s, our privacy policies, or to request review and/or removal of information collected by CL Zorbit’s, please call us toll free at 1-888-851-7094 or contact us at: privacy@carnegielearning.com or 200-215 Water St., St. John's, NL, Canada, A1C 6C9.
For questions about ongoing or potential research projects, please email research@carnegielearning.com.

To report technical issues with the Site or apps, or to submit feature requests, please Contact Us using the appropriate form.

As set forth below, residents of certain jurisdictions may have additional rights and choices regarding their personal data. If you are a resident of Canada, please see additional information directly below. If you are a resident of a U.S. state with specific rights, please see additional information here. Residents of the UK, please see additional information here. Residents of Brazil, please see additional information here.

Notice to Canadian Residents. Please note, you may withdraw consent at any time (subject to legal or contractual restrictions and reasonable notice). Subject to certain limits set out in the applicable laws, Canadian residents also have the right to request access to the personal information that CL Zorbit’s collects and to update or correct personal information if it is inaccurate. We may need to verify your identity before implementing your request.

Subject to applicable law, if you are a Canadian resident and would like to submit a request to access, correct, or update your personal information, or to withdraw consent to the processing of your personal data, you must submit your request to Steve Sernett by sending an email to privacy@carnegielearning.com or calling 1-888-851-7094. You may also use this contact to submit any requests for information on our privacy practices or to submit a complaint regarding our practices.

Your request or complaint must include your full name, street address, city, province, postal code, and an email address so that we are able to contact you if needed regarding this request.

We cannot properly process requests or complaints that do not come through the designated request mechanism or do not contain sufficient information to allow us to process your request. You may also be required to take reasonable steps as we determine from time to time in order to verify your identity and/or the authenticity of the request. Once your request is processed, absent exemptions, we will provide you with details regarding what personal information we have, how it is used, and with which third parties it is shared.

You and We confirm that it is our wish that this Privacy Policy, the Terms of Use, and all other related policies be drawn up in English. Vous reconnaissez avoir exigé la rédaction en anglais du présent document ainsi que tous les documents qui s'y rattachent.

U.S. State Specific Rights: Please note that we will take reasonable steps to accommodate your request, but may need to verify your identity before doing so.

Colorado, Connecticut, Utah, and Virginia. We set forth above the categories of personal data we process, the purpose for processing personal data, the categories of personal data shared, and the categories of third parties with whom personal data is shared. Residents of Virginia, Colorado, Connecticut, and Utah have certain privacy rights with respect to this data, as described below.

Exercise Your Rights If you are a Consumer residing in one these states (as defined in each state’s respective law) and would like to exercise your applicable, please do so through your account settings, if applicable, or submit your request by emailing privacy@carnegielearning.com.

In your request, please provide enough information to allow us to verify you are the person about whom we collected personal information. You must also describe your request with enough detail so that we can understand, evaluate, and respond to it. We can’t respond to your request if we can’t verify your identity. Making such a request does not require you to create an account with us, and we will only use the information you provide in a request to verify your identity.
- Access Your Personal Data/Obtain Your Information/Data Portability (CO, CT, UT, VA Residents) – You have the right to confirm whether we are processing your personal data and request to access such data, obtain a copy of the personal data previously provided by you to us and, to the extent feasible, in a readily usable format to allow data portability.
- Delete Your Personal Data (CO, CT, UT, VA Residents) – You have the Right to Delete your personal data.
- Correct Your Personal Data (CO, CT, VA Residents) – You have the Right to Correct the personal data we hold about you.
- Opt-Out of Sales of Your Personal Data and Targeted Advertising (CO, CT, VA, UT Residents) – You have the right to opt out of the sale of your data. CL Zorbit’s does not sell personal data to third parties for monetary compensation, as defined by Virginia and Utah laws and therefore does not offer this opt-out right to residents of Virginia or Utah. Colorado and Connecticut laws define “sale” broadly to include sharing for monetary or other valuable consideration. If you are a Colorado or Connecticut resident and would like to opt out of the sale of your personal data, please make a request using the email address listed above.
  - Cookie Based Opt Outs for Sale and Targeted Advertising. CL Zorbit’s engages in online advertising practices (and certain analytics or similar activities), which may be considered a “sale” as defined under CO and CT law and “targeted advertising” under VA, CI, CT and UT state laws. You may opt out of cookies set by third parties that may be considered “sales” and “targeted advertising” by adjusting your cookie settings using our Cookie Preference Center. Please also review the Third Party Advertising and Analytics/Privacy Controls section above for information on industry tools and device settings that may be available to you.
- Right to Appeal (CO, CT, VA Residents) - If, for any reason, you would like to appeal our decision relating to your request and you are a resident of Colorado, Connecticut, or Virginia, you have the right to submit an appeal and can do so using the email address listed above. Please include your full name, the basis for your appeal, and any additional information to consider.
Nevada. CL Zorbit’s does not currently sell your covered information as those terms are defined under applicable Nevada law. You may still submit an opt-out request and we will honor that request as required by Nevada law if CL Zorbit’s were to engage in such a sale in the future. If you are a Nevada resident or the parent of a Nevada Child User, and you would like to exercise this right, please email us at privacy@carnegielearning.com and put “Your Nevada Privacy Rights” in the subject field of your request.
California. If you are a California resident, please see our NOTICE TO CALIFORNIA RESIDENTS for additional information about your privacy rights and how to exercise them.
- California’s Shine the Light Law: CL Zorbit’s does not share personal information with third parties for the third parties’ direct marketing purposes without your specific consent (opt-in or opt-out).
- California Residents Under the Age of 18 Only: If you have created an account with the Sites, you may request that we remove content or information that you have publicly posted by sending an email message to privacy@carnegielearning.com that includes: your mailing address and a detailed description of the content or information. At our option, we may either remove your personal information (and not other user content) or remove all of the content and information. Note that if you have access to our Learning Platforms through an agreement with a School, we may not be able to remove your information and you may need to request removal from your School.

Other Countries

Notice for United Kingdom/European/Switzerland Residents. If you are a resident of the United Kingdom (UK), European Union or other EEA countries, or of Switzerland, the following information applies.

Purposes of processing and legal basis for processing: As explained above, we process personal information in various ways depending upon your use of our Sites. We process personal information on the following legal bases: (1) with your consent; (2) as necessary to perform our agreement to provide Sites; and (3) as necessary for our legitimate interests in providing the Sites where those interests do not override your fundamental rights and freedoms related to data privacy.

Right to lodge a complaint: Users that reside in the UK or EEA or Switzerland have the right to seek information and assistance or lodge a complaint about our data collection and processing actions with the supervisory authority where they reside. Contact details for data protection authorities are available here. UK: https://ico.org.uk/, EEA: https://edpb.europa.eu/about-edpb/board/members_en, Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/links/data-protection---switzerland.html.

Transfers: Personal information we collect may be transferred to, and stored and processed in, the United States or any other country in which we or our affiliates or subcontractors maintain facilities. We ensure that transfers of personal information to a third country or an international organization are subject to appropriate safeguards as described in Article 45-49 of the GDPR.

Withdraw consent: If we have collected personal information with your consent, you have the right to withdraw that consent at any time.

Access: You have the right to request access to personal information we collected about you and information about its sources, purposes, and sharing.

Correction: You have the right to request that we correct the personal information we hold about you if it is inaccurate or incomplete.

Erasure: You have the right to request that we erase data we have collected from you. Please note that we may have a reason to deny your deletion request or delete data in a more limited way than you anticipated, e.g., because of a legal obligation to retain it.

Portability: You have the right, in certain circumstances, to request that we provide your personal information to you in a format that can be transferred to another entity.

Restrict Processing: You have the right, in certain circumstances, to request that we limit our processing of your personal information if you are (1) contesting the accuracy of your personal information, (2) asserting that our processing is unlawful; (3) asserting that we no longer need to keep the information for reasons related to the establishment, exercise, or defense of legal claims, or you object to our processing. You have the right, in certain circumstances, to request that we limit our processing of your personal information if you are contesting the accuracy of your personal information; asserting that our processing is unlawful; asserting that we no longer need to keep the information for reasons related to the establishment, exercise, or defense of legal claims, or you object to our processing.

Object: You have the right to object to our processing if we are processing your personal information based on legitimate interests, using your personal information for direct marketing (including profiling), or processing your personal information for purposes of scientific or historical research and statistics.

Automated Decisionmaking: You have the right, in certain circumstances, not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects on you.

Verification Procedures: We must verify your identity for everyone’s protection, so we may require you to provide us with verification information prior to accessing any records containing personal information about you. We do this by:
Asking you to provide personal identifiers we can match against information we may have collected from you previously and confirm your request using the email or telephone account stated in the request; or
Having you submit your request through your account page, which will automatically verify your identity and will result in faster processing of your request.

Our Representative in the EEA:

Rickert Rechtsanwaltsgesellschaft mbH
- Carnegie Learning, Inc. –
Colmantstraße 15
53115 Bonn
Germany
Art-27-rep-carnegie@rickert.law

Notice to Residents of Brazil
If you are a resident of Brazil, the following information applies.

Purposes of processing and legal basis for processing: As explained above, we process personal information in various ways depending upon your use of our Sites. We process personal information on the following legal bases: (1) with your consent; (2) as necessary to perform our agreement to provide Sites; and (3) as necessary for our legitimate interests in providing the Sites where those interests do not override your fundamental rights and freedoms related to data privacy.

Right to lodge a complaint: Users that reside in Brazil have the right to seek information and assistance or lodge a complaint about our data collection and processing actions with the Agência Nacional de Proteção de Dados, “ANPD”, www.gov.br/anpd/pt-br.

Transfers: Personal information we collect may be transferred to, and stored and processed in, the United States or any other country in which we or our affiliates or subcontractors maintain facilities. We ensure that transfers of personal information to a third country or an international organization are subject to appropriate safeguards as described in Articles 33-36 of the Lei Geral de Proteção de Dados Pessoais (LGDP).

Withdraw consent: If we have collected personal information with your consent, you have the right to withdraw that consent at any time.

Access: You have the right to request access to personal information we collected about you and information about its use and sharing.

Correction: You have the right to request that we correct the personal information we hold about you if it is inaccurate, incomplete, or outdated.

Erasure: You have the right to request that we erase data we have collected from you in some cases. Please note that we may have a reason to deny your deletion request or delete data in a more limited way than you anticipated, e.g., because of a legal obligation to retain it.

Portability: You have the right, in certain circumstances, to request that we provide your personal information to you in a format that can be transferred to another entity.

Automated Decisionmaking: You have the right to request information about a decision based solely on automated processing, including profiling, and request a review of such decisions.

Verification Procedures: We must verify your identity for everyone’s protection, so we may require you to provide us with verification information prior to accessing any records containing personal information about you. We do this by:

Asking you to provide personal identifiers we can match against information we may have collected from you previously and confirm your request using the email or telephone account stated in the request; or

Having you submit your request through your account page, which will automatically verify your identity and will result in faster processing of your request.
We will use the information you provide for verification only for the purpose of verification. We may have a reason under the law why we do not have to respond to your request or respond to it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

NOTICE TO CALIFORNIA RESIDENTS

California Privacy Notice
This California Privacy Notice is effective as of August 29, 2023.

This notice supplements CL Zorbit’s Privacy Policy and applies only to California residents. This California Privacy Notice sets forth the disclosures and rights for California Consumers regarding their Personal Information, as required by the California Consumer Privacy Act of 2018 (“CCPA”), the California Privacy Rights Act of 2020 (“CPRA”), and any implementing regulations adopted thereunder. Terms (including defined capitalized terms) used in this California Privacy Notice have the same meanings given in the CCPA and CPRA and the associated regulations, unless otherwise defined.

EXERCISING YOUR CALIFORNIA RIGHTS

California Consumers have the right to request: (1) that we disclose to you what Personal Information we collect, use, disclose, and sell, including the right to request that we provide to you the categories and specific pieces of Personal Information we have collected about you (“Right to Know”); (2) that we delete the Personal Information we collect about you (“Right to Delete”); (3) that we correct inaccurate Personal Information we hold about you (“Right to Correct”), (4) to opt-out from the sharing of your Personal Information to a third party for cross-context behavioral advertising (i.e., targeted advertising) (“Right to Opt-Out of Sharing”), (5) to opt-out from the sale of their Personal Information (“Right to Opt-Out of Sale”), all subject to the meanings and exceptions set forth in the CCPA and CPRA. More information on each of these rights is below.

In your request, you must provide enough information to allow us to verify you are the person about whom we collected personal information, or their authorized representative. You must also describe your request with enough detail so that we can understand, evaluate, and respond to it. We can’t respond to your request if we can’t verify your identity. Making such a request does not require you to create an account with us, and we will only use the information you provide in a request to verify your identity.

Verifying Your Requests
We will take reasonable steps to verify your identity based upon the information you provide and the type of request you are making.

When you exercise your Right to Know, Right to Delete, and/or Right to Correct, we may ask that you provide us with information, beyond your full name, in order to verify your identity and fulfill your request. If we are unable to verify that the individual submitting the request is the same individual about whom we have collected information (or someone authorized by that individual to act on their behalf), we will not be able to process the request.

Agents
If you are an authorized representative submitting a request on a user’s behalf, please complete the applicable request per the instructions below. You may also make a request on behalf of your minor child. We will follow up to request a signed, written permission signed by the individual who is the subject of the request authorizing you to make the request on their behalf. The written permission must state your full legal name, the full legal name of the individual who is the subject of the request and needs to be clear about the permission granted. Alternatively, you may submit a copy of a power of attorney under Probate Code sections 4000-4465. In either case, please also indicate in your email the nature of your request. The consumer’s identity, in addition to your own, will need to be independently verified in order for us to be able to fulfill your request. We may also ask the consumer to directly confirm with us that they provided you permission to submit a request. Please keep in mind that if we do not receive adequate proof that you are authorized to act on the consumer’s behalf, we may deny the request.

Right to Know
California Consumers have the right to know what information we have collected about you (the categories and the specific pieces of information).

If you are a California Consumer and would like to exercise your Right to Know, please submit your request by emailing privacy@carnegielearning.com.

In order to have us provide specific pieces of information, we may require a signed declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request.

Right to Delete
California Consumers have the right to request that we delete information we have collected from you. If you are a California Consumer and would like to exercise your Right to Delete, please submit your request by emailing privacy@carnegielearning.com.

Please note that as part of the verification process, once you submit a request to delete, we may follow up and require you to confirm that you want your information deleted.

Right to Correct Inaccurate Information
California Consumers have the right to request that we correct inaccurate information we hold about you. If you are a California Consumer and would like to exercise your Right to Correct, please submit your request by emailing privacy@carnegielearning.com.

Right to Limit the Use and Disclosure of Sensitive Personal Information
Under the CPRA Regulations, a business must only provide the Right to Limit The Use and Disclosure of Sensitive Personal Information when Sensitive Personal Information is not collected or processed for the purpose of inferring characteristics about a consumer, or does not fall under certain statutory exceptions, pursuant to CPRA §1798.121. CL Zorbit’s use and disclosure of Sensitive Personal Information is not used for such purpose and/or falls within the statutory exceptions, and we therefore do not offer such this right at this time. Do Not Sell or Share

Right to Opt-Out of Sharing
California Consumers have the right to opt-out of the sharing of your Personal Information to a third party for cross-context behavioral advertising (i.e., targeted advertising), whether or not for monetary or other valuable consideration. If you are a California Consumer and would like exercise your Right to Opt-Out of Sharing, please submit your request by emailing privacy@carnegielearning.com.

Right to Opt-Out of Sale
California Consumers have the right to opt-out of the sale of your Personal Information. If you are a California Consumer and would like exercise your Right to Opt-Out of Sale, please submit your request by emailing privacy@carnegielearning.com.

Other Important Information for Do Not Sell or Share
CL Zorbit’s engages in online advertising practices (and certain analytics or similar activities), which may be considered a “sale” or “share” for cross-context behavioral advertising as defined in the CCPA and CPRA. To disable sharing through cookies set by 3rd parties that may be considered "sales" or “sharing” under the CCPA and CPRA, click here.

In addition, the Digital Advertising Alliance also offers tools for California consumers to send requests under the CCPA and CPRA to opt out of the sale of personal information by some or all of the participating companies.

Data Retention
We will retain all categories of personal information described in this California Privacy Notice for as long as it is reasonably necessary for the purposes set out in this California Privacy Notice, considering the time period reasonably necessary to: provide the Services to you; exercise the choices and rights you have requested; comply with our contractual obligations; enforce our terms for use of the Services; and, comply with legal and regulatory requirements. Except as noted differently on specific pages or apps, we retain your personal information while you have an account with us, or while you are using our Services or continuing to visit us.

Users Younger Than 16
CL Zorbit’s does not knowingly Sell or Share Personal Information of users younger than 16 years of age.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
California Consumers have the right to not receive discriminatory treatment for exercising CCPA and CPRA rights. We will not discriminate against you for exercising your CCPA and CPRA rights.

PERSONAL INFORMATION WE COLLECT
The Personal Information we collect about you will depend upon how you use the CL Zorbit’s Site or otherwise interact with us. Accordingly, we may not collect all of the below information about you.

In addition to the below, we may collect and/or use additional types of information and will do so after providing notice to you and obtaining your consent to the extent such notice and consent is required by the CCPA and CPRA.

Category of Personal Information Collected

Categories of Sources from which the Information was Collected

Business or Commercial Purpose(s) for which Information is Collected

Categories of Third Parties to whom this type of Personal Information is Disclosed for a Business Purpose

Categories of Third Parties to Whom this Type of Personal Information is Sold or Shared for Cross Contextual Behavioral Advertising

Identifiers

(such as name, email address, contact information, IP address)

We may collect this type of information from:

You,
Affiliated Companies,
School/Education Institution Customers,
Third party business partners,
Cookies and Tracking Technologies

We may use this type of information to:

to provide access to our products and services, or to provide quotes or offers for, and updates about, our products and services;
to send a confirmation notice to the Registrant of the registration;
to administer and manage accounts, including password resetting, responding to questions raised by Registrants, to contact the Registrant about any problems with the Registrant’s account or conduct on the Site;
to send out notifications or emails about the Site including information about current events, changes, improvements, upgrades, and rules of the Site;
for administrative, planning, product or service development, quality control and research purposes relating to our products and services;
for marketing purposes, but only where we have express or implied consent to contact someone or we are otherwise permitted by law to do so. Registrants may also opt out at any time by following the specific opt out instructions within the communications that we send;
to comply with the law and protect us, our consumers or the general public;
for other purposes described to you at the time of collection or otherwise with your consent or as consistent with this Privacy Policy.

We may disclose this type of information to:

Subsidiaries and Affiliates
School/Education Institution Customers
Service Providers,
Third parties or affiliated companies when you agree to or direct that we share your information with them.
Third parties who may acquire your information as a result of a merger, acquisition or otherwise ownership transition.
Law enforcement, government entities, or others if required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders);
Third parties we partner with for contests, sweepstakes, or promotions,
Third party advertising and analytics companies

Third party advertising, analytics, and other similar marketing business partners may have access to this data, and this may be considered a “sale” or “share” under the CCPA and CPRA under certain circumstances.

Any categories of Personal Information described in subdivision (v) of Section 1798.140

(such as name, signature, address, phone number, and other categories of information classified as “personal” under this California law)

Note: information in this category may overlap with other categories.

We may collect this type of information from:

You,
Affiliated Companies,
School/Education Institution Customers,
Third party business partners,
Cookies and Tracking Technologies

We may use this type of information to:

to provide access to our products and services, or to provide quotes or offers for, and updates about, our products and services;
to send a confirmation notice to the Registrant of the registration;
to administer and manage accounts, including password resetting, responding to questions raised by Registrants, to contact the Registrant about any problems with the Registrant’s account or conduct on the Site;
to send out notifications or emails about the Site including information about current events, changes, improvements, upgrades, and rules of the Site;
for administrative, planning, product or service development, quality control and research purposes relating to our products and services;
for marketing purposes, but only where we have express or implied consent to contact someone or we are otherwise permitted by law to do so. Registrants may also opt out at any time by following the specific opt out instructions within the communications that we send;

to comply with the law and protect us, our consumers or the general public;
for other purposes described to you at the time of collection or otherwise with your consent or as consistent with this Privacy Policy.

We may disclose this type of information to:

Subsidiaries and Affiliates
School/Education Institution Customers
Service Providers,
Third parties or affiliated companies when you agree to or direct that we share your information with them.
Third parties who may acquire your information as a result of a merger, acquisition or otherwise ownership transition.
Law enforcement, government entities, or others if required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders);
Third parties we partner with for contests, sweepstakes, or promotions,
Third party advertising and analytics companies

Commercial information

(such as information about your participation with a feature we offer)

We may collect this type of information from:

You,
Affiliated Companies,
School/Education Institution Customers,
Third party business partners,
Cookies and Tracking Technologies

We may use this type of information to:

to provide access to our products and services, or to provide quotes or offers for, and updates about, our products and services;
to send a confirmation notice to the Registrant of the registration;
to administer and manage accounts, including password resetting, responding to questions raised by Registrants, to contact the Registrant about any problems with the Registrant’s account or conduct on the Site;
to send out notifications or emails about the Site including information about current events, changes, improvements, upgrades, and rules of the Site;
for administrative, planning, product or service development, quality control and research purposes relating to our products and services;
for marketing purposes, but only where we have express or implied consent to contact someone or we are otherwise permitted by law to do so. Registrants may also opt out at any time by following the specific opt out instructions within the communications that we send;
to comply with the law and protect us, our consumers or the general public;
for other purposes described to you at the time of collection or otherwise with your consent or as consistent with this Privacy Policy.

We may disclose this type of information to:

Subsidiaries and Affiliates
School/Education Institution Customers
Service Providers,
Third parties or affiliated companies when you agree to or direct that we share your information with them.
Third parties who may acquire your information as a result of a merger, acquisition or otherwise ownership transition.
Law enforcement, government entities, or others if required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders);
Third parties we partner with for contests, sweepstakes, or promotions,
Third party advertising and analytics companies

Third-party advertising, analytics, and other similar marketing business partners may have access to this data, and this may be considered a “sale” or “share” under the CCPA and CPRA under certain circumstances.

Internet or other electronic network activity information

(such as information about the web browser and operating system you are using, the website or ad that referred you to our Site or areas of the Site that you visited.)

We may collect this type of information from:

You,
Affiliated Companies,
School/Education Institution Customers,
Third party business partners,
Cookies and Tracking Technologies

We may use this type of information to:

to provide access to our products and services, or to provide quotes or offers for, and updates about, our products and services;
to send a confirmation notice to the Registrant of the registration;
to administer and manage accounts, including password resetting, responding to questions raised by Registrants, to contact the Registrant about any problems with the Registrant’s account or conduct on the Site;
to send out notifications or emails about the Site including information about current events, changes, improvements, upgrades, and rules of the Site;
for administrative, planning, product or service development, quality control and research purposes relating to our products and services;
for marketing purposes, but only where we have express or implied consent to contact someone or we are otherwise permitted by law to do so. Registrants may also opt out at any time by following the specific opt out instructions within the communications that we send;
to comply with the law and protect us, our consumers or the general public;
for other purposes described to you at the time of collection or otherwise with your consent or as consistent with this Privacy Policy

We may disclose this type of information to:

Subsidiaries and Affiliates
School/Education Institution Customers
Service Providers,
Third parties or affiliated companies when you agree to or direct that we share your information with them.
Third parties who may acquire your information as a result of a merger, acquisition or otherwise ownership transition.
Law enforcement, government entities, or others if required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders);
Third parties we partner with for contests, sweepstakes, or promotions,
Third party advertising and analytics companies

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

This category includes, for example, images, video, or audio recordings.

We may collect this type of information from:

You,

Affiliated Companies

School/Education Institution Customers

Third party business partners

We may use this type of information to:

to provide access to our products and services, or to provide quotes or offers for, and updates about, our products and services;
for administrative, planning, product or service development, quality control and research purposes relating to our products and services;
for marketing purposes, but only where we have express or implied consent to contact someone or we are otherwise permitted by law to do so. Registrants may also opt out at any time by following the specific opt out instructions within the communications that we send;
to comply with the law and protect us, our consumers or the general public;
for other purposes described to you at the time of collection or otherwise with your consent or as consistent with this Privacy Policy.

We may disclose this type of information to:

Subsidiaries and Affiliates
School/Education Institution Customers
Service Providers,
Third parties or affiliated companies when you agree to or direct that we share your information with them.
Third parties who may acquire your information as a result of a merger, acquisition or otherwise ownership transition.
Law enforcement, government entities, or others if required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders);
Third party advertising and analytics companies

Inferences drawn from any of the information identified above to create a profile about You

(such as preferences, characteristics, predispositions and behaviors)

We may collect this type of information from:

You,
Affiliated Companies,
School/Education Institution Customers,
Third party business partners,
Cookies and Tracking Technologies

We may use this type of information to:

to provide access to our products and services, or to provide quotes or offers for, and updates about, our products and services;
to send a confirmation notice to the Registrant of the registration;
to administer and manage accounts, including password resetting, responding to questions raised by Registrants, to contact the Registrant about any problems with the Registrant’s account or conduct on the Site;
to send out notifications or emails about the Site including information about current events, changes, improvements, upgrades, and rules of the Site;
for administrative, planning, product or service development, quality control and research purposes relating to our products and services;
for marketing purposes, but only where we have express or implied consent to contact someone or we are otherwise permitted by law to do so. Registrants may also opt out at any time by following the specific opt out instructions within the communications that we send;
to comply with the law and protect us, our consumers or the general public;
for other purposes described to you at the time of collection or otherwise with your consent or as consistent with this Privacy Policy.

We may disclose this type of information to:

Subsidiaries and Affiliates
School/Education Institution Customers
Service Providers,
Third parties or affiliated companies when you agree to or direct that we share your information with them.
Third parties who may acquire your information as a result of a merger, acquisition or otherwise ownership transition.
Law enforcement, government entities, or others if required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders);
Third parties we partner with for contests, sweepstakes, or promotions,
Third party advertising and analytics companies

Third party advertising, analytics, and other similar business partners may have access to this data, and this may be considered a “sale” or “share” under the CCPA and CPRA under certain circumstances.

TABLE OF CONTENTS

1. Personal, Sensitive, and Non-Personal Data We Collect and How We Use and Disclose It

2. Additional Details about our Data Practices

3. Third Party Advertising and Analytics/Privacy Controls

4. Your Choices

5. Security

6. Third Party Content and Links

7. Consent to Transfer

8. Data Retention

9. Changes to This Privacy Policy

10. Contact Us

11. Jurisdiction-Specific Rights

12. California Privacy Notice