First Effective Date: July 28, 2017
Replaced by new policy: October 30, 2020
EU-U.S. PRIVACY SHIELD AND SWISS-U.S. PRIVACY SHIELD FRAMEWORKS
Lessonly has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States, and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.
HUMAN RESOURCES DATA WITHIN THE CONTEXT OF THE EMPLOYMENT RELATIONSHIP
In compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Principles, Lessonly commits to resolve complaints about your human resources data privacy and our collection, use, or disclosure of your personal information. European and Swiss individuals with inquiries regarding the handling of their human resources data or complaints concerning our HR privacy practices should first contact Lessonly at:
Lessonly commits to cooperate with the EU data protection authorities (DPAs) and Swiss Federal Data Protection and Information Commissioner, and comply with the advice given by the panel and/or Commissioner with regard to human resources data transferred from the EU and/or Switzerland in the context of the employment relationship.
Lessonly is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
Lessonly has implemented processes intended to protect user information and maintain security of data that we process. Each account holder is assigned a unique user name and password, which is required to access their account. It is your responsibility to protect the security of this login information. When you enter sensitive information (such as your login information) on our site, we encrypt the transmission of that information using secure socket layer technology (SSL). We have attempted to protect Lessonly’s servers by locating them in areas with security procedures, use of firewalls and implementing other generally available security technologies. These safeguards help prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of data, but no guarantee can be made that you information and data will be secure from intrusions and unauthorized release to third parties.
As part of the Lessonly Service, we store the lessons you build and any data that was collected from those lessons. We respect the privacy of all users, and consider all data that is collected to be private. Lessonly may access this data only for the purpose of providing the Lessonly Service, preventing or addressing service or technical problems, at a Customer’s request in connection with customer support matters, or as may be required by law. Lessonly will not distribute or sell your information to a third party, except as disclosed in this policy. When you utilize the Lessonly Service from outside of the United States, data is submitted and transferred into the United States and you hereby consent to such transfer.
Lessonly collects information under the direction of our clients (“Clients”), and has no direct relationship with the individuals whose personal information it processes. We collect information for our Clients, if you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our Service, please contact the Client that you interact with directly.
We collect email addresses from those who contact us via email, and ask for information such as email address and name when you sign up for an account with Lessonly. The information we collect is not distributed or sold to a third party. It will only be used to communicate with you about your Lessonly account, and where needed as part of certain Lessonly features. You may update, change or delete your account information at any time by accessing your information on your account or contact us at email@example.com or by contacting us by telephone or postal mail at the contact information listed below. We will respond to your request to access personal information within 30 days.
We will retain information we process on behalf of our Clients for as long as your account is active or as needed to provide services to our Client. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
If you wish to subscribe to our newsletter, we will use your name and email address to send the newsletter to you. Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page or you can contact us at firstname.lastname@example.org.
WEB SERVER LOGS
For statistical purposes, Lessonly will gather certain information automatically and store it in log files. These log files contain standard information collected by web servers, such as Client IP addresses, browser type, internet service provider (ISP), operating system, etc. This information is only used internally, and is not distributed or sold to a third party. Lessonly uses this information, which does not identify individual users, to analyze trends, to administer the Lessonly website and to gather demographic information about its user base as a whole. Lessonly does not link this automatically collected data to personal information.
We may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
We also may provide your personal information to companies that provide services to help us with our business activities such as, but not limited to, our hosting or analytics provider. These companies are authorized to use your personal information only as necessary to provide these services to us.
Lessonly is potentially liable under the EU-U.S. and Swiss-U.S. Privacy Shield Principles in cases of onward transfer of data about EU and Swiss individuals to a third party acting on behalf of Lessonly as its agent if the third party engages in a manner inconsistent with the Privacy Shield Principles and Lessonly is responsible for the event giving rise to damages.
Lessonly shall ensure that any third party to which we disclose personal information provides the same level of privacy protection as is required by the Privacy Shield Principles and agrees in writing to provide an adequate level of privacy protection. Prior to disclosing personal information to a third party that is not acting as Lessonly’s agent, we will notify you of such disclosure and provide you with the choice to opt-out of the disclosure.
We provide you the opportunity to “opt-out” of having your personal information used or disclosed for certain purposes. Specifically, we offer you the opportunity to opt-out of: (1) the disclosure of your personal information to a third party that is not acting as an agent of Lessonly, and (2) the use of your personal information for a purpose other than the purpose for which it was originally collected or subsequently authorized by you. To limit the use and disclosure of your personal information, please email us at email@example.com.
When we collect sensitive personal information (such as personal information about your medical or health conditions, racial or ethnic origin, political, religious, or philosophical opinions and beliefs, trade union membership, or sex life) from you, we will first obtain your affirmative, express (“opt-in”) consent prior to disclosing the sensitive personal information to a third party or using it for a purpose other than the purpose for which it was originally collected or subsequently authorized by you.
ACCESS TO PERSONAL INFORMATION
You have the right to access the personal data we hold. Upon request, we will provide you with access to the personal information that we hold about you. You may also may correct, amend, or delete the personal information we hold about you. Your right to access your personal information may be restricted in exceptional circumstances, including, but not limited to, when the burden or expense of providing this access would be disproportionate to the risks to your privacy in the case in question, or when the rights of persons other than you would be violated by the provision of such access. If we determine that your access should be restricted in a particular instance, we will provide you with an explanation of our determination and respond to any inquiries you may have.
To request access to your personal information or to request us to correct, amend, or delete your personal information, please e-mail us at support@Lessonly.com or contact us by telephone or postal mail at the contact information listed above. We will respond to your request within 30 days.
Technologies such as cookies, beacons, tags, and scripts are used by Lessonly and our marketing partners, affiliates, or analytics or customer service providers. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
BEHAVIORAL TARGETING / RE-TARGETING
We partner with a third party to either display advertising on our Web site or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by contacting us at firstname.lastname@example.org. Please note this does not opt you out of being served ads. You will continue to receive generic ads.
Certain web browsers and other devices you may use to access the website may permit you to indicate your preference that you do not wish to be “tracked” online. At this time, this website and the Lessonly Service do not respond to “Do Not Track” signals.
We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at email@example.com.
SOCIAL MEDIA WIDGETS
We give you the opportunity to use integration services by logging into your existing tools. This service will authenticate your identity and provide you the option to share certain personal information to use with the Lessonly Service.
COMPLIANCE WITH CHILDREN’S ONLINE PRIVACY PROTECTION ACT
As a business service, Lessonly does not target its offering toward, and does not knowingly collect any personal information from, users under thirteen (13) years of age.
YOUR CALIFORNIA PRIVACY RIGHTS
California law provides that California residents have a right to request businesses to tell them how their personal information has been shared with third parties, if at all, for the third parties’ direct marketing purposes. To make such a request, please contact us at the contact information provided above.
If you are an European Economic Area data subject, please visit our GDPR consumer rights notice.