4. DO WE USE COOKIES AND OTHER
TRACKING
TECHNOLOGIES?
In
Short: We may use cookies and other tracking
technologies to collect and store your
information.
We may use cookies and similar
tracking technologies (like web beacons and pixels) to access or
store information. Specific information about how we use such
technologies and how you can refuse certain cookies is set out in
our Cookie Notice
.
5. HOW DO WE HANDLE YOUR
SOCIAL
LOGINS?
In Short:
If you choose to register or log in to our
Services using a social media account, we may have access to
certain information about you.
Our Services offer you the ability to
register and log in using your third-party social media account
details (like your Facebook or Twitter logins). Where you choose to
do this, we will receive certain profile information about you from
your social media provider. The profile information we receive may
vary depending on the social media provider concerned, but will
often include your name, email address, friends list, and profile
picture, as well as other information you choose to make public on
such a social media platform.
We will use the information we receive
only for the purposes that are described in this privacy notice or
that are otherwise made clear to you on the relevant Services.
Please note that we do not control, and are not responsible for,
other uses of your personal information by your third-party social
media provider. We recommend that you review their privacy notice to
understand how they collect, use, and share your personal
information, and how you can set your privacy preferences on their
sites and apps.
6. HOW LONG DO WE KEEP YOUR
INFORMATION?
In Short:
We keep your information for as long as
necessary to fulfill the purposes outlined
in this privacy notice unless otherwise required by
law.
We will only keep your personal
information for as long as it is necessary for the purposes set out
in this privacy notice, unless a longer retention period is required
or permitted by law (such as tax, accounting, or other legal
requirements). No purpose in this
notice will require us keeping your personal information for longer
than
the period of time in which users
have an account with us
.
When we have no ongoing legitimate
business need to process your personal information, we will either
delete or anonymize such information, or, if
this is not possible (for example, because your personal information
has been stored in backup archives), then we will securely store
your personal information and isolate it from any further processing
until deletion is possible.
7. HOW DO WE KEEP YOUR
INFORMATION
SAFE?
In Short:
We aim to protect your personal information
through a system of
organizational and
technical security measures.
We have implemented appropriate and
reasonable technical and
organizational
security measures designed to protect the security of any personal
information we process. However, despite our safeguards and efforts
to secure your information, no electronic transmission over the
Internet or information storage technology can be guaranteed to be
100% secure, so we cannot promise or guarantee that hackers,
cybercriminals, or other
unauthorized third
parties will not be able to defeat our security and improperly
collect, access, steal, or modify your information. Although we will
do our best to protect your personal information, transmission of
personal information to and from our Services is at your own risk.
You should only access the Services within a secure
environment.
8. DO WE COLLECT INFORMATION
FROM
MINORS?
In
Short: We do not knowingly collect data from
or market to children under 18
years of age.
We do not knowingly solicit data from
or market to children under 18 years of age. By using the Services,
you represent that you are at least 18 or that you are the parent or
guardian of such a minor and consent to such minor dependent’s use
of the Services. If we learn that personal information from users
less than 18 years of age has been collected, we will deactivate the
account and take reasonable measures to promptly delete such data
from our records. If you become aware of any data we may have
collected from children under age 18, please contact us at
admin@edstruments.com
.
9. WHAT ARE YOUR PRIVACY
RIGHTS?
In
Short:
You may review, change, or
terminate your account at any time.
Withdrawing your
consent: If we are relying on your consent to
process your personal information,
which may be express and/or implied consent depending on the
applicable law, you
have the right to withdraw your consent at any time. You can
withdraw your consent at any time by contacting us by using the
contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS
NOTICE?
" below.
However, please note that this will not
affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the
processing of your personal information conducted in reliance on
lawful processing grounds other than consent.
Opting out of marketing and
promotional communications:
You can unsubscribe from our marketing and promotional
communications at any time by
or by contacting us using the
details provided in the section "
HOW CAN
YOU CONTACT US ABOUT THIS NOTICE?
" below. You will then be
removed from the marketing lists. However, we may still communicate
with you — for example, to send you service-related messages that are
necessary for the administration and use of your account, to respond
to service requests, or for other non-marketing purposes.
Account
Information
If you would at any time like to review or
change the information in your account or terminate your account, you
can:
Upon your request to terminate your
account, we will deactivate or delete your account and information
from our active databases. However, we may retain some information in
our files to prevent fraud, troubleshoot problems, assist with any
investigations, enforce our legal terms and/or comply with applicable
legal requirements.
Cookies and similar
technologies: Most Web browsers are set to accept
cookies by default. If you prefer, you can usually choose to set
your browser to remove cookies and to reject cookies. If you choose
to remove cookies or reject cookies, this could affect certain
features or services of our Services. You may also opt out of interest-based
advertising by advertisers on our
Services.
If you have questions or comments about your
privacy rights, you may email us at
admin@edstruments.com.
10. CONTROLS FOR DO-NOT-TRACK
FEATURES
Most web browsers and some mobile
operating systems and mobile applications include a Do-Not-Track (
"DNT") feature or setting you
can activate to signal your privacy preference not to have data
about your online browsing activities monitored and collected. At
this stage no uniform technology standard for recognizing and implementing DNT
signals has been finalized. As such, we do not
currently respond to DNT browser signals or any other mechanism that
automatically communicates your choice not to be tracked online. If
a standard for online tracking is adopted that we must follow in the
future, we will inform you about that practice in a revised version
of this privacy notice.
11. DO CALIFORNIA RESIDENTS
HAVE SPECIFIC PRIVACY
RIGHTS?
In Short:
Yes, if you are a resident of California, you
are granted specific rights regarding access to your personal
information.
California Civil Code Section 1798.83,
also known as the "Shine The
Light" law, permits
our users who are California residents to request and obtain from
us, once a year and free of charge, information about categories of
personal information (if any) we disclosed to third parties for
direct marketing purposes and the names and addresses of all third
parties with which we shared personal information in the immediately
preceding calendar year. If you are a California resident and would
like to make such a request, please submit your request in writing
to us using the contact information provided
below.
If you are under 18 years of age,
reside in California, and have a registered account with Services,
you have the right to request removal of unwanted data that you
publicly post on the Services. To request removal of such data,
please contact us using the contact information provided below and
include the email address associated with your account and a
statement that you reside in California. We will make sure the data
is not publicly displayed on the Services, but please be aware that
the data may not be completely or comprehensively removed from all
our systems (e.g., backups, etc.).
CCPA
Privacy Notice
The California Code of
Regulations defines a
"resident"
as:
(1) every individual who is in the
State of California for other than a temporary or transitory purpose
and
(2) every individual who is domiciled
in the State of California who is outside the State of California
for a temporary or transitory purpose
All other individuals are defined as
"non-residents."
If this definition of "resident" applies to you, we must
adhere to certain rights and obligations regarding your personal
information.
What categories of personal
information do we collect?
We have collected the following
categories of personal information in the past twelve (12)
months:
|
Category
|
Examples
|
Collected
|
|
A.
Identifiers
|
Contact details, such as real
name, alias, postal address, telephone or mobile contact
number, unique personal identifier, online identifier,
Internet Protocol address, email address, and account
name
|
YES
|
|
B. Personal information
categories listed in the California Customer Records
statute
|
Name, contact information,
education, employment, employment history, and financial
information
|
YES
|
|
C. Protected classification
characteristics under California or federal
law
|
Gender and date of
birth
|
YES
|
|
D. Commercial
information
|
Transaction information,
purchase history, financial details, and payment
information
|
NO
|
|
E. Biometric
information
|
Fingerprints and
voiceprints
|
NO
|
|
F. Internet or other similar
network activity
|
Browsing history, search
history, online behavior
, interest
data, and interactions with our and other websites,
applications, systems, and
advertisements
|
YES
|
|
G. Geolocation
data
|
Device
location
|
YES
|
|
H. Audio, electronic, visual,
thermal, olfactory, or similar
information
|
Images and audio, video or
call recordings created in connection with our business
activities
|
NO
|
|
I. Professional or
employment-related information
|
Business contact details in
order to provide you our Services at a business level or job
title, work history, and professional qualifications if you
apply for a job with us
|
NO
|
|
J. Education
Information
|
Student records and directory
information
|
NO
|
|
K. Inferences drawn from other
personal information
|
Inferences drawn from any of
the collected personal information listed above to create a
profile or summary about, for example, an individual’s
preferences and characteristics
|
YES
|
|
L. Sensitive Personal
Information
|
Account login information
,
contents of email or text messages
and
precise geolocation
|
YES
|
We will use and retain the
collected personal information as needed to provide the Services or for:
- Category
A - As long as the user has an account with us
- Category
B - As long as the user has an account with us
- Category
C - As long as the user has an account with us
- Category F -
As long as the user has an account with us
- Category G -
As long as the user has an account with us
- Category K - As long as the user has an account with
us
- Category L - As long as the user has an account with
us
Category L information
may be used, or disclosed to a service provider or
contractor, for additional, specified purposes. You have
the right to limit the use or disclosure of your sensitive
personal information.
We may also collect other
personal information outside of these categories through
instances where you interact with us in person, online, or
by phone or mail in the context of:
- Receiving help through our
customer support channels;
- Participation in customer
surveys or contests; and
- Facilitation in the
delivery of our Services and to respond to your
inquiries.
How do we use and
share your personal
information?
Edstruments collects and
shares your personal information through:
- Targeting
cookies/Marketing cookies
More
information about our data collection and
sharing practices can be found in this
privacy notice
.
You may contact us
or by referring to the
contact details at the bottom of this
document.
If you are using an
authorized agent
to exercise your right to opt out we may deny a
request if the
authorized
agent does not submit proof that they have
been validly
authorized
to act on your behalf.
Will your
information be shared with anyone
else?
We may disclose your
personal information with our service providers
pursuant to a written contract between us and each
service provider. Each service provider is a
for-profit entity that processes the information
on our behalf, following the same strict privacy
protection obligations mandated by the
CCPA.
We may use your
personal information for our own business
purposes, such as for undertaking internal
research for technological development and
demonstration. This is not considered to be "selling" of
your personal information.
Edstruments has not sold
or shared any personal information to third parties
for a business or commercial purpose in the
preceding twelve (12) months.
Edstruments
has
disclosed the following categories of personal
information to third parties for a business or
commercial purpose in the preceding twelve (12)
months:
- Category A.
Identifiers, such as contact details like
your real name, alias, postal address,
telephone or mobile contact number, unique
personal identifier, online identifier,
Internet Protocol address, email address,
and account name.
-
Category B.
Personal Information, as defined in the
California Customer Records law, such as your
name, contact information, education,
employment, employment history, and financial
information.
- Category C.
Characteristics of protected classifications
under California or federal law, such as
gender or date of birth.
- Category F.
Internet or other electronic network
activity information, such as browsing
history, search history, online behavior,
interest data, and interactions with our and
other websites, applications, systems, and
advertisements.
- Category G.
Geolocation data, such as device
location.
- Category
K. Inferences drawn from any of the
personal information listed above to
create a profile or summary about, for
example, an individual's preferences
and characteristics.
- Category L.
Sensitive personal information, such as
account login
information
, contents of email or
text messages
and
precise geolocation
.
Your
rights with respect to your personal
data
Right
to request deletion of the data —
Request to
delete
You can
ask for the deletion of your personal
information. If you ask us to delete
your personal information, we will
respect your request and delete your
personal information, subject to certain
exceptions provided by law, such as (but
not limited to) the exercise by another
consumer of his or her right to free
speech, our compliance requirements
resulting from a legal obligation, or
any processing that may be required to
protect against illegal
activities.
Right
to be informed — Request to
know
Depending
on the circumstances, you have a right
to know:
- whether
we collect and use your personal
information;
- the
categories of personal information
that we collect;
- the
purposes for which the collected
personal information is used;
- whether
we sell or share personal information
to third parties;
- the
categories of personal information
that we sold, shared, or disclosed for
a business purpose;
- the
categories of third parties to whom
the personal information was sold,
shared, or disclosed for a business
purpose;
- the
business or commercial purpose for
collecting, selling, or sharing
personal information; and
- the specific
pieces of personal information we
collected about you.
In
accordance with applicable law, we are
not obligated to provide or delete
consumer information that is
de-identified in response to a consumer
request or to re-identify individual
data to verify a consumer
request.
Right
to Non-Discrimination for the Exercise
of a Consumer’s Privacy
Rights
We will
not discriminate against you if you
exercise your privacy
rights.
Right to
Limit Use and Disclosure of Sensitive
Personal Information
If the
business collects any of the following:
- social
security information, drivers' licenses,
state ID cards, passport numbers
- account
login information
- credit card
numbers, financial account information, or
credentials allowing access to such
accounts
- racial or
ethnic origin, religious or philosophical
beliefs, union membership
- the contents
of email and text, unless the business is
the intended recipient of the
communication
- genetic
data, biometric data, and health data
- data
concerning sexual orientation and sex life
you have the
right to direct that business to limit its
use of your sensitive personal information
to that use which is necessary to perform
the Services.
Once a
business receives your request, they are no
longer allowed to use or disclose your
sensitive personal information for any other
purpose unless you provide consent for the
use or disclosure of sensitive personal
information for additional purposes.
Please note
that sensitive personal information that is
collected or processed without the purpose
of inferring characteristics about a
consumer is not covered by this right, as
well as the publicly available
information.
To exercise
your right to limit use and disclosure of
sensitive personal information, please email admin@edstruments.com
or
submit a
data subject
access
request
.
Verification
process
Upon
receiving your request, we will need to
verify your identity to determine you
are the same person about whom we have
the information in our system. These
verification efforts require us to ask
you to provide information so that we
can match it with information you have
previously provided us. For instance,
depending on the type of request you
submit, we may ask you to provide
certain information so that we can match
the information you provide with the
information we already have on file, or
we may contact you through a
communication method (e.g.,
phone or email) that you have
previously provided to us. We may also
use other verification methods as the
circumstances
dictate.
We will
only use personal information provided
in your request to verify your identity
or authority to make the request. To the
extent possible, we will avoid
requesting additional information from
you for the purposes of verification.
However, if we cannot verify your
identity from the information already
maintained by us, we may request that
you provide additional information for
the purposes of verifying your identity
and for security or fraud-prevention
purposes. We will delete such
additionally provided information as
soon as we finish verifying
you.
Other
privacy
rights
- You may
object to the processing of your
personal information.
- You may
request correction of your personal
data if it is incorrect or no longer
relevant, or ask to restrict the
processing of the information.
- You can
designate an
authorized
agent to make a request under
the CCPA on your behalf. We may deny a
request from an
authorized
agent that does not submit
proof that they have been validly
authorized
to act on your behalf in
accordance with the CCPA.
- You may
request to opt out from future selling
or sharing of your personal
information to third parties. Upon
receiving an opt-out request, we will
act upon the request as soon as
feasibly possible, but no later than
fifteen (15) days from the date of the
request submission.
To
exercise these rights, you can contact
us
or by
referring to the contact details at the
bottom of this document. If you have a
complaint about how we handle your data, we
would like to hear from you.
12. DO
VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY
RIGHTS?
In
Short: Yes, if
you are a resident of Virginia, you may
be granted specific rights regarding
access to and use of your personal
information.
Virginia
CDPA Privacy
Notice
Under the
Virginia Consumer Data Protection Act
(CDPA):
"Consumer"
means a natural person who is a
resident of the Commonwealth acting only
in an individual or household context. It
does not include a natural person acting
in a commercial or employment context.
"Personal data"
means any information that is
linked or reasonably linkable to an
identified or identifiable natural person.
"Personal data"
does not include de-identified data
or publicly available information.
"Sale
of personal data"
means the exchange of personal data
for monetary consideration.
If this
definition
"consumer"
applies to you, we must adhere to
certain rights and obligations regarding
your personal data.
The
information we collect, use, and disclose
about you will vary depending on how you
interact with
Edstruments and our Services. To
find out more, please visit the following
links:
Your
rights with respect to your personal
data
- Right to
be informed whether or not we are
processing your personal data
- Right to
access your personal data
- Right to
correct inaccuracies in your personal
data
- Right to
request deletion of your personal
data
- Right to
obtain a copy of the personal data you
previously shared with us
- Right to
opt out of the processing of your
personal data if it is used for targeted
advertising, the sale of personal data,
or profiling in furtherance of decisions
that produce legal or similarly
significant effects (
"profiling"
)
Edstruments has
not sold any personal data to third parties
for business or commercial purposes. Edstruments will
not sell personal data in the future
belonging to website visitors, users, and
other consumers.
Exercise your
rights provided under the Virginia
CDPA
More information
about our data collection and sharing
practices can be found in this privacy
notice
.
You may
contact us by email at admin@edstruments.com
,
by submitting a data subject
access request
, or by
referring to the contact details at the
bottom of this document.
If you are
using an
authorized
agent to exercise your rights, we
may deny a request if the authorized
agent does not submit proof that
they have been validly authorized
to act on your
behalf.
Verification
process
We may
request that you provide additional
information reasonably necessary to verify
you and your consumer's request. If you
submit the request through an authorized
agent, we may need to collect
additional information to verify your
identity before processing your
request.
Upon
receiving your request, we will respond
without undue delay, but in all cases,
within forty-five (45) days of receipt.
The response period may be extended once
by forty-five (45) additional days when
reasonably necessary. We will inform you
of any such extension within the initial
45-day response period, together with the
reason for the extension.
Right to
appeal
If we
decline to take action regarding your
request, we will inform you of our
decision and reasoning behind it.
If you wish
to appeal our decision, please email us at
admin@edstruments.com
. Within
sixty (60) days of receipt of an appeal,
we will inform you in writing of any
action taken or not taken in response to
the appeal, including a written
explanation of the reasons for the
decisions. If your appeal if denied, you
may contact the
Attorney
General to submit a
complaint.
13.
DO WE MAKE UPDATES TO THIS
NOTICE?
In
Short: Yes, we will update
this notice as necessary to stay
compliant with relevant
laws.
We may
update this privacy notice from time to
time. The updated version will be
indicated by an updated
"Revised"
date and the updated version will
be effective as soon as it is
accessible. If we make material changes
to this privacy notice, we may notify
you either by prominently posting a
notice of such changes or by directly
sending you a notification. We encourage
you to review this privacy notice
frequently to be informed of how we are
protecting your
information.
14.
HOW CAN YOU CONTACT US ABOUT
THIS
NOTICE?
If you
have questions or comments about this
notice, you may
email us at
admin@edstruments.com.
Edstruments,
United States
15.
HOW CAN YOU REVIEW, UPDATE, OR
DELETE THE DATA WE COLLECT FROM
YOU?
Based
on the applicable laws of your country,
you may have the right to request access
to the personal information we collect
from you, change that information, or
delete it.
To
request to review, update, or delete
your personal information, please fill
out and submit a
data subject
access
request
.