Privacy Policy | Conversya Hub

Conversia Privacy Policy

Effective: February 8, 2023

This Privacy Policy applies to any websites, software, applications, or interactive features or online services, owned and operated by Conversia, LTD (hereinafter “Conversia,” “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 information we collect offline in connection with the use of the Sites.

Please read this Privacy Policy carefully. Please review our Terms of Service, 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.

TABLE OF CONTENTS

INFORMATION WE COLLECT

Information You Provide Directly

Information We Collect Automatically

"Do Not Track" Signals

Information We Receive From Schools and School-Affiliated Third Parties

Invite-a-Colleague Features

Social Media Features

Information We Receive From Other Third Parties

HOW DOES Conversia USE THE INFORMATION COLLECTED?

WHEN DOES Conversia SHARE INFORMATION?

Companies Providing Services on our Behalf

Schools and School-Affiliated Third Parties

When You Agree to Receive Information from Third Parties or Request That We Share Your Information

Business and Legal Purposes

Business Transfers

Sweepstakes, Contests, and Promotions

THIRD-PARTY ADVERTISING AND ANALYTICS COMPANIES AND SIMILAR THIRD PARTIES

SECURITY

THIRD-PARTY LINKS OR CONTENT

CONSENT TO TRANSFER OF DATA

CHANGES TO THIS PRIVACY POLICY

INFORMATION FOR CALIFORNIA RESIDENTS

INFORMATION FOR NEVADA RESIDENTS

NOTICE FOR CANADIAN RESIDENTS

NOTICE FOR EUROPEAN/SWITZERLAND RESIDENTS

INFORMATION WE COLLECT

Conversia collects information about you directly through our Sites, automatically when you visit the Sites, and sometimes from third parties. Some of this information may be considered “personal information” under various applicable laws. We consider information that identifies you as a specific, identified individual (such as your name and email address) to be personal information. We will also treat additional information, including IP addresses and cookie identifiers, as “personal information” where required by applicable law. Note that we may de-identify personal information so that it is non-personal, such as aggregating or converting it to a code, sometimes using a function commonly known as “hash”. We will treat de-identified information as non-personal to the fullest extent allowed by applicable law. If we combine non-personal information with personal information, then we will treat the combined information as personal information under this Privacy Policy.

Information You Provide Directly

Visitors may provide certain information directly to the Sites, such as when you contact us for information about our products, customer support, or research inquiries, when you register for an account, or when you sign-up for our email mailing list.

In order to obtain access to and use our learning platforms, we ask you to register to become a member. During this member registration process, and through other interactions on our Sites and across the learning platforms, we collect information that teachers and administrators provide to us as well as information about their students, including, but not limited to, your name, the school or school district you work for, the physical address of your school, your job title, the grades and curricula you teach, your student roster, your email address, and your phone number. When you register for the learning platforms, we will also ask you to create a password. When you use the learning platforms, we collect information about your interactions with the learning platforms, including the courses you use. Some of our learning platforms offer live courses, which may be recorded and made available for later viewing within the Learning Platform.

We may also ask you for feedback about the usage of various products and services as well as satisfaction with those products and services.

Information We Collect Automatically

We 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 (“Usage Information”). Usage Information may include your browser types and versions and operating system you are using, search terms and results within the Sites and all areas of the Sites that you visit, date and time you visit the Sites, the length of your stay on certain courses or pages and your language settings, among other information. In addition, we automatically collect your IP address or other unique identifier (“Device Identifier”) for any computer, mobile phone or other device you may use to access the Sites. A Device Identifier is a number that is automatically assigned to your device used to access the Sites, and our servers identify your device by its Device Identifier. We may be able to collect or infer your approximate location through information we collect, such as IP address.

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. You may choose to enable these options. However, enabling these options may prevent you from using many of the core features and functions available on our Sites.

The technologies that may be used to collect Usage Information include the following:

Cookies.

When you use our Sites, Conversia 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 remains on your computer after the browser has been closed). Conversia 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 Conversia experience so that your visit is as relevant and as valuable to you as possible.

For more information on cookies, visit http://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.

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

“Do Not Track” Signals

Some browsers have "Do Not Track" features that allow you to tell a website not to track you. These features are not all uniform and there is no consensus as to what "Do Not Track" means in this context. Conversia uses commercially reasonable efforts to detect and process "Do Not Track" signals, but may not respond to "Do Not Track" signals except as specifically required by law. To find out more about "Do Not Track", please visit http://www.allaboutdnt.com.

Information We Receive From Schools and School-Affiliated Third Parties

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 information 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.

Invite-a-Colleague Features

You may choose to provide us names or other contact information for a colleague to enable them to create an account with the Sites. If you send a communication through the Sites, the information 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 information relating to other people to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Social Media Features

The Sites may permit you to interact with a third party platform (such as Google, Facebook, Instagram, Twitter, LinkedIn, and Pinterest) and the Sites, 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 information about you and your use of the Sites and the third-party service. These third-party social networking companies may collect information 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 information 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 information 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 information 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 information we collect in connection with Social Media Features is subject to this Privacy Policy; the information the third party platform collects is subject to the third party’s privacy practices (including whether the third party shares information with us, the types of information shared, and your choices about what is visible to others on the third-party platform).

Information We Receive From Other Third Parties.

We may receive certain information 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 information 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 information we have about you. We use this information 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 information collected and stored by third parties is subject solely to the third party’s privacy practices.

HOW DOES CONVERSIA USE THE INFORMATION COLLECTED?

Conversia may use the information it collects for a number of purposes, including:

To allow you to participate in the Sites and learning platforms, such as to provide information you have requested and provide services in accordance with our agreements with Schools, including to process your registration (including verifying information you provide is active and valid) and to provide customer service
To analyze and provide academic and learning outcomes based on students’ use of the services;
To contact you with regard to your use of the Sites or similar administrative communications, including changes to the policies governing the Sites;
To provide information and promotional materials about the products and services we offer;
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;
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 Conversia’s everyday business needs, such as administration and improvement of our Sites and related services;
For other internal business and legal purposes, including investigation of information security and information asset protection-related incidents and to protect against fraud or other potentially illegal activities, to enforce our Terms of Use, to comply with all applicable laws and regulations and Conversia’s corporate reporting obligations, and to enforce Conversia’s agreements;
For external academic research and scholarship.

WHEN DOES CONVERSIA SHARE INFORMATION?

Conversia may share non-personal information, such as aggregate user statistics, de-identified or hashed information (such as hashed email addresses), and Usage Information, with third parties, unless prohibited by applicable law or our agreement with a School. For example, Conversia 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 information in its discretion, including for targeted advertising purposes.

Conversia does not share your personal information 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.

We may share the information we have collected about you as described in this Privacy Policy, including:

Companies Providing Services on our Behalf

Conversia 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 Conversia's privacy policy. Our third-party service providers may be located in the U.S., Canada or other foreign jurisdictions.

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 information we collected 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 information 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 information and the information 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.

When You Agree to Receive Information from Third Parties or Request That We Share Your Information

We may share information when you direct us to do so. For example, you may be presented with an opportunity to receive marketing offers from a third party or you may engage with Social Media Features or other third- party application or feature, through which information about you is shared. Please note that we are not responsible for the privacy practices of third parties. If you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly.

Business and Legal Purposes

We may share user information, including personal information, to third parties, including, but not limited to, for the following purposes: enforce our Terms of Use; protect Conversia’s property, services and legal rights; prevent physical harm to the persons or property of others; prevent fraud or potentially illegal activities against Conversia and others; support auditing, compliance, and corporate governance functions; test, correct, and improve our content, applications, and services; develop new applications, products, and services; analyze academic and learning outcomes and preferences; for external academic research and scholarship; comply with subpoenas, court orders, or similar legal processes, including from law enforcement agencies, regulators and courts; comply with any and all applicable laws; and we may also use Device Identifiers, including IP addresses, to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies in our discretion.

Business Transfers

Conversia also may share personal or other information with its subsidiaries and affiliates, primarily for business and operational purposes.

Conversia may also share personal or other information in the event of an acquisition, reorganization or merger of Conversia or its assets, including, without limitation, during the course of any due diligence process, Conversia reserves the right to disclose and transfer all information related to the Sites, including personal information, Sweepstakes, Contests, and 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 Information 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).

THIRD- PARTY ADVERTISING AND ANALYTICS COMPANIES AND SIMILAR THIRD PARTIES

Conversia 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 Usage Information, aggregated or de-identified 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 information over time, including your visits to and activity on the Sites as well as other websites and online services.

Your Advertising Choices: Some of these third parties may be members of the Network Advertising Initiative (“NAI”) or Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. Both NAI and DAA provide information regarding procedures for opting-out of targeted online advertising from participating companies. For information from NAI about opting out, click here. For information from DAA about opting out click here. If you are a California resident, please see our “California Privacy Notice” for more information about your rights.

We also use Google Analytics, which uses cookies and other technologies to collect and analyze information about use of the Site and provide other reports. This service may also collect information regarding your use of other websites, apps, and online resources. For information about opting out from Google, click here, and to download the Google Analytics opt-out browser add-on from Google, click here.

SECURITY

Conversia takes commercially reasonable steps to help protect and secure personal information. 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, Conversia cannot ensure or warrant the security of any information you transmit to us. Therefore, you understand, acknowledge, and agree that you transmit certain personal information to the Sites at your own risk.

THIRD PARTY LINKS OR CONTENT

The Sites may contain links to other web sites or include other content hosted and served by third parties that Conversia 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 information, 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 Conversia and over which we have no control. We may collect Usage Information through Conversia content appearing on third party sites. Conversia is not responsible for the privacy practices of any third party.

CONSENT TO TRANSFER OF DATA

Conversia is a United States company. If you are a user of the Sites outside of the United States, 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, including 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 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.

WHAT ARE YOUR CHOICES ABOUT YOUR INFORMATION?

Members can review, modify, and delete certain information related to your use of our Sites by accessing your Conversia 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 hello@conversya-hub.com. For users of the learning platforms, you may need consent from the applicable School to modify information we hold.

Canadian residents please refer to the “Notice for Canadian Residents” section below for further details regarding your choices.

You can unsubscribe from email by following the instructions contained within the email you receive from us.

Members can also manage your communication settings in our Subscription Center when logged into your account.

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.

If you sign up to receive SMS or MMS messages from Conversia, you may unsubscribe from any SMS or MMS messages received by replying “STOP”.

CHANGES TO THIS PRIVACY POLICY

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, Conversia 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 information 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 information 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 new Privacy Policy in order to continuing using the Sites.

INFORMATION FOR CALIFORNIA RESIDENTS

A. California Privacy Notice

Under the California Consumer Privacy Act or “CCPA”, California residents have certain privacy rights with respect to the personal information we collect. If you are a California resident with whom we have a direct business or potential business relationship, this section applies to you. Because Conversia collects personal information through the Sites from individuals acting on behalf of a business in the context of providing a service, at this time Conversia is not subject to most provisions of the CCPA.

Conversia does not sell your personal information for monetary compensation, however depending on the types of activities on the Sites, Conversia may provide a tool to opt-out of certain cookies and other tracking technology, including, if applicable, some that may be considered “sales” under CCPA. In some cases we may provide an opt-out tool even where we are not sharing your personal information in exchange for valuable consideration. To opt out from the collection or sharing of information through certain types of cookies, including those that may be considered “sales” under California law, open the Cookie Preference Center and click on Targeting Cookies/Do Not Sell My Personal Information and move the toggle switch to the left.

The Digital Advertising Alliance (“DAA”) also offers tools for California residents to send requests under the CCPA to opt out of the sale of personal information by participating companies (https://www.privacyrights.info/).

Conversia also collects personal information as a service provider on behalf of and only in the ways permitted by our customers. If you are a California resident and would like to submit a request to access or delete information under the CCPA, please direct your request to your School administrator.

California’s Shine the Light Law

Conversia 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 hello@conversya-hub.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.

INFORMATION FOR NEVADA CONSUMERS

Conversia 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 Conversia 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 hello@conversya-hub.com and put “Your Nevada Privacy Rights” in the subject field of your request.

For any questions about Conversia, our privacy policies, or to request review and/or removal of information collected by Conversia, please contact us at: hello@conversya-hub.com.

Conversia, LTD

hello@conversya-hub.com

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

NOTICE FOR 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 Conversia 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 your personal information or to withdraw consent to the processing of your personal data, you must submit your request by sending an email to hello@conversya-hub.com. 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.

NOTICE FOR UNITED KINGDOM/EUROPEAN/SWITZERLAND RESIDENTS

Notice to Individuals Located in the United Kingdom (UK) and European Economic Area (EEA) and Switzerland

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-dpb/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 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.

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.

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.

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.

Service Providers

In order to provide and support our products, conversya-hub may contract with third parties and share information required to carry out these services with these third parties. These service providers provide support services, such as hosting the learning platforms and operating their features, or performing other administrative services. In such cases, all third parties are required to abide by this policy. conversya-hubtakes reasonable steps to release personal information collected from students only to service providers and third parties who are capable of and have agreed to maintain the confidentiality and security of that information and to use that personal information only to provide the applicable service to us or on our behalf.

Administrative and Legal Reasons

We may disclose personal information about students to third parties when necessary to protect the security or integrity of the learning platforms; take precautions against liability; respond to judicial process; or provide information to law enforcement agencies or for an investigation on a matter related to public safety. We may also disclose personal information about students in connection with a merger or the sale of teacher-assistant’s assets or interest in the learning platforms, or other similar change in ownership (including, during the course of any due diligence process), provided that any subsequent owner of student’s personal information has agreed to abide by teacher-assistant’s then-current student privacy policy.

Research and Statistical Purposes

conversya-hub uses de-identified and aggregate data about students’ use of our learning platforms for product development, research or other purposes. To de-identify data, we remove all direct and indirect personal identifiers. These identifiers include, but are not limited to, name, ID number, birth date, teacher name, class and school identifications. conversya-hubagrees not to attempt to re-identify any de-identified data, and to restrict any third parties to whom it discloses such data from attempting to re-identify any de-identified data. We may store de-identified data indefinitely. Schools, school districts, and individuals may ask for their data to be excluded from any de-identified data sets. To request such exclusion, please email hello@conversya-hub.com.

In addition, for research and other purposes, conversya-hubmay transfer de-identified data to third parties. For example, we may share information such as problems attempted, answers or hint requests for each step of the problem, and associated time stamps. We review all requests for such de-identified data sets, and we require all recipients of de-identified data sets to agree to the conversya-hubTerms of Use, which prohibit, among other things, any attempts to re-identify the de-identified data and any commercial use of the data.

In connection with research studies, conversya-huband/or its partners may publish or discuss aggregate data about student performance and results. Such publications never reference individual information, only aggregate statistics. Research projects that make use of student data may be reviewed by an Institutional Review Board (IRB) which is responsible for approving the goals and procedures of the study, including those related to maintaining privacy of information. The IRB may or may not require parental or student notification or approval. Schools or school districts provide prior consent to any research that involves interaction with the schools and their students’ information. conversya-hubis committed to abiding by IRB recommendations and requirements.

As part of our commitment to continual improvement, conversya-hub may field test new application content and test versions of features within our products, including through studies which employ random assignment. We may also partner with third-party researchers to conduct such research. If the research is not exempt from IRB review, an Institutional Review Board (IRB) will review the goals and procedures of the study, including those related to maintaining privacy of information.

Sweepstakes, Contests, and 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 provide for the sharing of information collected in connection with the Promotion beyond those instances described elsewhere in this Privacy Policy.

Third-Party Analytics Services

We may work with analytics providers to provide us with information regarding the use of our learning platforms. These third parties may set and access their own tracking technologies on your devices (including cookies and web beacons), and they may otherwise collect or have access to information about you, including Usage Information. With respect to Children, to the extent there is any collection of information through tracking technologies, it is used only for providing support for internal operations as needed to provide the learning platforms.

Third-Party Links or Content

The learning platforms may contain links to other web sites or include other content hosted and served by third parties that conversya-hub does not control. 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 conversya-hub and over which we have no control. We may collect Usage Information through conversya-hub content appearing on third-party sites. conversya-hubis not responsible for the privacy practices of any third party.

Consent to Transfer of Data

conversya-hubis a United States company. If you are a user of the learning platforms outside of the United States, by using the learning platforms 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, your personal information may be processed in the country in which it was collected and in other countries, including 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 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.

Conversia LTD is the operator of these learning platforms and any questions regarding this Privacy Policy and the collection or use of personal information should be directed to:

Conversia LTD
hello@conversya-hub.com

Accessing the learning platforms through Private Provider

The learning platforms may be made available through agreements we have with organizations who provide specialized education services to students, but who are not directly associated with a School (“Private Provider”). In those cases, we or the Private Provider (rather than the School) will obtain any necessary consent from a student’s parent or legal guardian as required by law.

When students access the learning platforms through a Private Provider, conversya-hubacts as a service provider on behalf of and in the ways permitted by the agreement with the Private Provider. Accordingly, Private Providers may have access to all of the information we collect from students that is associated with the students’ accounts with the Private Provider. If a Private Provider is working in connection with a student’s School, they may share or ask us to share student information about students associated with that School.

If you are the parent of a Child who uses our learning platforms through a Private Provider and have questions about our privacy practices, or would like to request to access or delete your Child’s information, please contact us as indicated in the section above. If you would like more information about how the Private Provider handles your personal information, please contact the Private Provider.

Information for California Residents

conversya-hubcollects personal information from users of the learning platforms as a service provider on behalf of and only in the ways permitted by the applicable School agreement. conversya-hubdoes not sell personal information collected through the learning platforms or share that information with third parties for their own direct marketing purposes. If you are a California consumer and would like to submit a request to access or delete information under the California Consumer Privacy Act (CCPA), please direct your request to your School administrator.