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Minute School Privacy Policy

Minute School Inc. and its Affiliates (“Minute School”, “we”, “our” or “us”) values our members, including you (“you” or “your”) and we respect your privacy and personal information which is information about an identifiable individual (as defined by applicable privacy or data protection laws).  This privacy policy (this “Policy”) applies to your use of our websites, mobile application, and interactions with us, and/or services (“Products”) and describes the kinds of personal information we collect about you, how we use it, how we protect it, and under what circumstances we share it with third parties. This Policy also describes the decisions you can make about your personal information.  You may require us to change, amend, or delete the personal information that you have provided to us at any time.  “Affiliates” means any entity directly or indirectly controlling or controlled by, or under control with, Minute School Inc..

If this Policy changes in the future, we will post an updated version on our website at www.minuteschool.com (the “Website”). We recommend that you check this Website periodically in order to review our current Policy. You can tell if this Policy has changed by checking the effective date that appears at the bottom of this Policy.  Depending on the circumstances, we may, in our discretion, also decide to send you a notice, such as via email, that the Policy was changed. If you continue to use our Products after the Policy changed or notice of the change has been given, you will be deemed to have accepted such changes.

 

1 Information We Collect

When you use our Products, we collect the following types of information:

(a) Account information: When you register to use our Products you will need to create an account with us and you may choose your privacy settings.  In order to create an account, you will need to provide us with your name, email address, age, gender, current school, past schools, year of study, academic interests, non-academic interests, and type of member (which may include student, parent, or educator).

(b) General usage data: When you use our Products we may collect technical properties of hardware and software utilized in conjunction with our Products.  For example, we may collect the type and model of hardware, the type and version of operating system and web browser you are using, the GPS information and IP address of your hardware, the URL being requested, length of request, connection speed, and the date and time associated with this information.  When you use our Products we may also collect information about your use of the Products.  For example, we may collect what relationships with other members you form (including the formation of groups of members); the date, time, and recipient of messages you send in the Products; what searches and queries you perform in the Products; the date, time, and subject of events you set up; what courses and content you consume while using the Products; the date, time, and content of information you transmit through various channels in the Products; what areas members of the Products visit and what services members access most frequently; and how long you use our Products in each session and overall, features you use in our Products.  If you choose to use our invitation service to tell a friend about Minute School and our Products, we will ask you for information to send the invitation, such as your friend’s email address.  We will automatically send your friend a one-time email inviting them to visit the Website to learn about Minute School and become a member. Your friend’s email will then be permanently deleted unless they choose to register for an account.

(c) Purchase and Payment Information: While payments made through our Products using a virtual currency are processed through a third party, we may collect information to administer, manage, and fulfill the purchases you make.  For example, we may collect the quantity of virtual currency purchased, your name, email address, account information, what is purchased and the price, the date and time of the purchase, the quantity of virtual currency purchased, how much you paid for the virtual currency, whether payment was made, method of payment, purchase history, and if you re-purchased.

(d) Third party information: If necessary to fulfill our identified purposes, we may combine the information you submit to us with information obtained from other sources or third party offerings.  Such information includes (but is not limited to) the webpage members view prior to arriving at our website and upon leaving our website; and search term and search result information you conduct on other websites. We may also collect tokens and personal information you choose to make available through social networking sites such as (but not limited to) Facebook®, Google Plus®, and Twitter® so you can use single sign-on and we can optimise your experience with us.  We treat all such personal information in accordance with this Policy and the terms and conditions between us and such third parties, if any, may also apply. However, the third party’s own use of your personal information in such cases will be determined by your agreement(s) with the third party, unless that third party is one of our service providers.

(e) Quality assurance and customer service: Your customer service telephone calls and emails with us and our service providers and your feedback about our Products, if any, may be recorded, logged, and/or monitored for quality assurance and customer service purposes such as to assist in addressing your inquiries, troubleshooting, training and analytics to identify trends and make improvements to our Products and customer service.  As part of the recording and logging of the calls and emails, we will collect information like the identity of the caller or sender of email, the date and time of the call or email, and the subject and resolution of the issue or of the feedback.

(f) Cookies: In addition, when you visit our Website or use our Minute School mobile application (the “App”), we collect certain information about your activity on our Website or in the App, as described below under the heading “Our use of Cookies, Log Files, Web Beacons, and Embedded Scripts”.

Some of this information would not by itself identify you to us or be personally identifiable and is therefore considered non-personal information. If we combine any such non-personal information with other personal information available to us, the combined information will be treated as personal information in accordance with this Policy.

 

2 Our Use of Information We Collect

We use the personal information we collect about you:

(a) to understand and meet your needs and preferences, and/or to provide you with our Products, for example:

(i) for purposes related to the billing, activation, provision (including tailoring the Products for you, matching you with schools in your area based on the location information we collect from you, providing you with service related communications), maintenance, support, trouble shooting, resolving of disputes, deactivation, upgrade or update of Products, and sales and marketing of the Products;

(ii) to process and fulfill your purchase, send you emails to confirm your purchase status and shipment, send you Products or goods you purchase, and allow you to pay for Products and goods you purchase;

(iii) to track whether a visitor to the Website and user of the App is a member, to serve personalized ads to members who have previously consented to receive ads, and/or to pre-populate certain fields (like account and payment related information) to make your use of the Website and/or App simpler and more efficient;

(iv) to display your name, email address, photo, and profile information to people in the networks specified in your privacy settings and to always display your username within the Products;

(v) to ensure Products are technically functioning as intended and to help identify and troubleshoot issues;

(vi) to fulfill or enforce any agreements or notices we provide and are associated with a particular Product (“Notices”);

(vii) to manage or respond to your inquiries;

(b) to develop new and enhance existing Products including to communicate with you about them using various means, for example to make available or send to you upgrades or updates, or notices of upgrades or updates of Products;

(c) to manage and develop our business and operations, for example;

(i) to detect, monitor, investigate, mitigate or attempt to prevent fraud and technical or security issues or to protect our property;

(ii) to allow for business continuity and disaster recovery operations;

(iii) to enforce our legal rights;

(iv) for statistical purposes, including to analyze our performance;

(d) to meet legal and regulatory requirements and to respond to emergency situations, for example:

(i) to respond to court orders, warrants or other lawful requests or legal processes;

(ii) to provide emergency assistance in situations that may threaten the life or physical safety of you or others; or

(iii) for any other purposes for which you have consented, such as those that may be set out in Notices, and other purposes as permitted or required by any applicable law.

Notwithstanding anything to the contrary contained in this Policy, we may remove personal identifiers from your information and maintain and use it in a de-identified form that may be combined with other information to generate aggregated information. Such de-identified and/or aggregated information will be deemed to be owned by us and we shall have unrestricted title, rights, and interest to the de-identified and/or aggregated information which may include, without limitation, the right to use, distribute, transmit, transfer, license, trade, rent, share, assign, and sell the de-identified and/or aggregated information.  We will retain your personal information as long as necessary for the fulfillment of the identified purposes or as otherwise necessary to comply with applicable laws.

You may update your communication preferences anytime by writing us at support@minuteschool.com.  Please note that generally you may not opt-out of service related communications (for example, if our Website is temporarily suspended for maintenance, we might send you an email) which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.

 

3 To whom we Disclose your Personal Information

In accordance with this Policy, we may share your personal information:

(a) within Minute School and/or with our service providers such as a cloud service provider in Canada, the United States, and the European Economic Area for data storage, or a provider of technical support, credit card processing, and sender of emails on our behalf;

(b) with our financial, insurance, legal, accounting or other advisors that provide professional services to us;

(c) if we have your consent;

(d) with third parties involved in providing our Products to you which may include payment processors;

(e) and any and all information about your use of the Products with other members of the Products that are you are connected with and that you have consented to us sharing your information with;

(f) as necessary to complete any transactions while using our Products;

(g) respond to a subpoena, order, legal process, or government request;

(h) protect, establish or exercise our legal rights or defend against legal claims;

(i) investigate, detect, suppress, prevent or take action regarding illegal or prohibited activities, suspected fraud, situations involving potential threats to the reputation or physical safety of any person;

(j) as otherwise required by law; or

(k) if we are to be sold, merged, or amalgamated or substantially all of our assets are to be sold or disposed of, your personal information may be transferred to a potential purchaser if, and to the extent necessary, it is required for the purposes of deciding whether to proceed with the proposed transaction and completing it. If such a sale, merger, acquisition, or disposal is completed, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner that is consistent with this Policy.  Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information.

 

4 Your Decisions About Your Personal Information

When you use the Products, please keep in mind: (a) your profile (and any personal information in your profile) may be publicly available in accordance with the privacy settings you select; (b) information you post or share with others, such as personal information, courses, notes, comments, messages, photos, videos, or other content and/or information, may be publicly available and associated with your username in accordance with the privacy settings you select; (c) the Products contain functionality permitting any member to search for and to use such public content; and (d) when you make use of our content features to share information with other members of the Products (e.g., sending a personal message to another member, uploading files, or creating other content), generally neither you nor us can remove such content, so please exercise caution and discretion before sharing such information.  Please note the default setting on the Products makes your profile and information you share or post with others public.  You can change your privacy settings to make your material anonymous and restrict what information you share with us (such as location information).  Minute School works hard to maintain this functionality and to respect your wishes.  No system is perfect, however, and it is possible that material you designate as anonymous may inadvertently become public.  It’s also possible that you could make an error.  If you need help with privacy settings, email us: support@minuteschool.com.

Our Products include: (i) services like Facebook Connect to give you the option to publish information on your Facebook wall about your activities using the Products and for you to publish information from your Facebook wall in your profile page in the Products so you may share the information with others in your network; and (ii) social media features, such as the Facebook Like button, which may collect your IP address, which page you are visiting in the Website, and may set a cookie to enable the feature to function properly. Social media features may be hosted by a third party, in which case your interactions with these features are governed by the privacy policy of the company providing it.

At any time you can contact us to: stop receiving emails from us; request removal of your personal information from our blog or community forum; review the personal information held by us in connection with your account; withdraw your consent for our use and disclosure of your information; request a list of third parties to which we may have provided your personal information; close your account; and amend your personal information, by writing to us at support@minuteschool.com.  In some cases, we may not be able to remove your personal information from the Products, in which case we will let you know if we are unable to do so and why.  You can always unsubscribe from receiving promotional emails from us by simply clicking the “unsubscribe” link provided at the bottom of every promotional email from us.

If you contact us to do any of the things listed in the paragraph above, we may require you to provide sufficient personal information to allow us to identify you and tell you about the existence, use and disclosure of your personal information and this personal information will only be used for this purpose. If you contact us about your personal information, we will respond to your request within a reasonable time and at minimal cost or no cost to you in accordance with applicable laws.

Generally, you may withdraw at any time your consent for us to collect, use, and disclose your personal information in accordance with this Policy, subject to legal or contractual restrictions and reasonable notice. As such, we may continue to collect, use, and disclose your personal information as may be required to provide you with our Products, and to the extent that we are contractually obligated to do so or as necessary to enforce any contractual obligations you may have with us. If you refuse to provide us with the information we require or later contact us to withdraw your consent for us to use and disclose your personal information, we may no longer be able to provide you with our Products.

 

5 Our Use of Cookies, Log Files, Web Beacons, and Embedded Scripts

When you visit the Website and/or use the App, we collect certain information by automated means, such as through server log files, cookies (text files sent to and stored on your device when you access the Website and/or use the App), authentication tokens, web beacons (also known as clear GIFs and pixel tags, which may be used to transmit information back to the Website and/or App), and embedded scripts (programming code that is designed to collect information about your interactions with the Website and/or App, such as the links you click on, and which is active only when you are accessing the Website and/or App).  We use clear GIFs in our HTML-based emails to let us know which emails have been opened by recipients.  This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.

The information we collect in this manner may include details about the hardware and software used to access the Website and/or App (such as make, model, GPS location and/or IP address, browser type and operating system type and version, and App version), referring URLs and information on actions taken or interaction with our digital assets.

We may use third-party web analytics services to help us analyze how visitors use the Website and/or the App. We may permit these third parties to operate directly on the Website and/or in the App, use their own technology (such as cookies or web beacons), and collect information about you on our behalf.

When you visit our Website and/or use our App and if you opt-in to receiving targeted advertisements, we may allow some third parties (such as advertising networks and data analytics companies) to collect your IP address, upload cookies to your computer, or use other technologies such as JavaScript and web beacons (also known as “1×1 GIFs”) to learn about your online activities over time and across different websites, to measure the effectiveness of their ads, and to personalize advertising content.  In this way, they may compile information about where individuals using your computer or browser saw their advertisements and determine which advertisements are clicked.  Your browser and/or App settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. However, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” visit http://www.allaboutdnt.com.

In some instances, we may also combine information we receive about you from third parties with information we collect through the Website and/or the App.

 

6 Security

We aim to provide you with a safe experience. We have in place certain physical, technical, and administrative safeguards designed to appropriately protect the security and privacy of your personal information against loss, theft, and unauthorized access, disclosure, copying, use, or modification. Please note, however, that we cannot guarantee that the measures we maintain will guarantee the security of the information.

We limit access to your personal information within Minute School to individuals with a need to know.

Your personal information may be collected, used, processed, transferred, and retained in multiple countries including Canada, the United States, and the European Economic Area which may be outside the region in which you are situated and may have different privacy or data protection legislation, and may therefore be subject to the laws of these countries. If you are a resident of the European Economic Area or a country which restricts data transfers outside of that jurisdiction or region without your consent, by using our Products, you consent to your personal information being transferred outside of the European Economic Area or your country for processing or storage by or on behalf of us.

 

7 Links to Other Sites

We provide links on our Website and in our App to third party sites we think you will enjoy. These sites operate independently of us and may have established their own privacy and security policies. Any personal information you provide on linked pages or other sites is subject to that third party’s privacy policy. We strongly encourage you to review these policies at any site you visit. This Policy does not apply to such linked pages or other sites, and we are not responsible for the content or practices of any linked websites which are provided solely for your convenience.

 

8 Children’s Online Privacy Protection

The Products are not intended for use by children under 16 years of age.  We do not knowingly collect or use any personal information from any children under 13 years of age. If we become aware that we have unknowingly collected personal information from a child under the age of 13, we will make commercially reasonably efforts to delete such personal information from our database.  If you believe that we might have any information from or about a child under 13 years of age, please contact us at support@minuteschool.com.

 

9 California Residents – Your California Privacy Rights

If you are a California resident and you have questions about our practices with respect to sharing information with third parties and affiliates for their direct marketing purposes, please send your request by email to support@minuteschool.com or write to us at Minute School Inc., 408 Speckled Alder Street, Suite 42, Waterloo, Ontario, Canada, N2V 2S9. You must put the statement “Your California Privacy Rights” in the subject field of your email or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

 

10 Questions or Comments

If you have any questions or comments or wish to make a complaint about this Policy, please feel free to contact us by email support@minuteschool.com, or by delivery in person, by courier or by the mail, to us at Minute School, 684 Belmont Avenue West, Suite 302, Kitchener, Ontario, Canada, N2M 1N6, or by calling us at 226-894-0421. If you contact us about your personal information, we will respond to your request within a reasonable time and at minimal cost or no cost to you in accordance with applicable laws.  Depending on the circumstances and applicable laws, we may refuse to process certain access requests (for example, access requests that are unreasonably repetitive or systematic, would be extremely impractical or require disproportionate technical effort).

Effective Date: August 10, 2016

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