This Notice applies to California residents who are users of our Services. The provisions in this Notice are intended to provide disclosures in compliance with the California Consumer Privacy Act (“CCPA”) and other relevant California laws and regulations.
Please note that we are providing the following disclosures and rights regarding personal information in this section in the interest of transparency and our commitment to privacy; such disclosures and rights are not intended to waive any applicable exemptions under the CCPA.
If you are a visually impaired individual, an individual who has another disability or an individual who seeks support in other language, you may access your privacy rights by emailing us at [EMAIL].
a. Personal information we collect
We may collect, or have collected, the following categories of personal information:
- Identifiers
- Commercial information
- Audio, electronic, visual, or similar information
- Internet or other electronic activity information
- Geolocation data
- Inferences drawn from any of the above
b. How we use personal information
We use the personal information we collect about you for the following purposes:
- in order to comply with applicable law and regulations;
- in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings; or
- to the extent we have obtained your consent.
- to operate, maintain or improve the Website, the Services or our business;
- to contact you or respond to your requests or inquiries;
- to support auditing, legal or compliance functions;
- to provide the Services;
- to create and manage online accounts;
- to send promotional materials, alerts and other communications, which may be through the Website or outside of the Website, such as via e-mail or through third party websites and/or apps;
- to optimize the Services and understand usage patterns and user behavior;
- for targeted advertising, and to understand the usefulness to you of the advertisements or content that have been delivered to you;
- for systems and data security;
- to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about the users of our Sites is among the assets transferred;
- to communicate about, and administer participation in, special events; promotions, programs, offers, surveys, contests and market research; and/or
- to maintain our internal records.
c. To whom we disclose personal information
We limit our disclosure of the categories of personal information above to our service providers for one or more business purposes. “Business purposes,” means the reasonably necessary and proportionate use of personal information for our operational purposes, other purposes described in this Privacy Policy, for the operational purposes of our service providers and contractors, as well as other purposes compatible with the context in which the personal information was collected.
We do not and have not sold personal information to third parties for any monetary value. We do gather personal information from users via cookies and other tracking technologies as part of our targeted advertising initiatives, which is technically considered a “sale” and/or “share” of personal information under the CCPA, even though we do not receive monetary payment for sharing or disclosing personal information to these third parties. Accordingly, during last 12 months (from the last updated date listed at the top of this Privacy Policy), we have “sold” or “shared” the following categories of personal information as those terms are defined under the CCPA:
- Identifiers
- Commercial information
- Audio, electronic, visual, or similar information
- Internet or other electronic network activity information
- Geolocation data
- Inferences
The categories of third parties to whom we may sell or share your personal information include, where applicable, vendors and other parties involved in cross-context behavioral advertising.
d. Your privacy rights
Subject to certain limitations, California residents have the following rights under California law:
- Right to know and access. You have the right to know what personal information we collect, use, disclose, and sell and/or share, as those terms are defined under applicable law. You may ask us to provide you a portable copy of this information up to two times in a rolling twelve-month period.
- Right to delete and erase. You have the right to request under certain circumstances that we, as well as our service providers and contractors, delete the personal information that we collect about you.
- Right to correct. You have the right to request the correction of inaccurate personal information.
- Right to non-discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.
- Right to opt out of sale and/or sharing. You have the right to opt-out of the sale and/or sharing of your personal information.
- Right to limit use and disclosure. You have the right to limit the use or disclosure of your sensitive personal information to only the uses necessary for us to provide goods or services to you. We will not use or disclose your sensitive personal information after you have exercised your right unless you subsequently provide consent for the use of your sensitive personal information for additional purposes.
- Sharing with third parties for their own direct marketing purposes. We do not disclose personal information to third parties for their own purposes without your consent. If you wish to request information regarding such practices under California’s “Shine the Light” Law, please Contact Us. You must include your full name, email address, and postal address in your email or mail request so that we can verify your California residence and respond.
If you would like to make a request and exercise your rights described above, , please send your request(s) using one of the following methods:
● Emailing us at info@wqlearning.com
● Visting Your Privacy Choices webform.
You may designate an authorized agent to submit a request on your behalf, and if so, we may require proof of the agent’s authorization by you and/or verification of the agent’s own identity.
Please note that any request you submit to us is subject to an identification and residency verification process as permitted under California law. Generally, a rights request must include:
- Sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which must include, at a minimum, your first and last name and email address.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to the request.
You are not required to create an account with us to submit a request. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
We do not charge a fee to process or respond to your verifiable consumer request unless its excessive, repetitive, manifestly unfounded, or in accordance with applicable law. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will confirm receipt of your request within 10 business days. Except where otherwise noted, we will respond to your request within forty-five (45) days after receipt and we reserve the right to extend the response time by an additional forty-five (45) days when reasonably necessary and provided consumer notification of the extension is made within the first forty-five (45) days.
Please note that all requests are subject to certain exceptions under California law, which may vary. If you are a visually impaired customer, a customer who has another disability or a customer who seeks support in other language, you may access your privacy rights by emailing us at info@wqlearning.com.
e. Notice of right to opt-out of sale/sharing
You have the right to opt-out of the sale and/or sharing of your personal information by a business. As noted above, we may “sell” and/or “share” your personal information for purposes of cross-context behavioral advertising. You can opt out of such sale or sharing by emailing us at info@wqlearning.com or visiting Your Privacy Choices.
We do not knowingly sell or share the personal information of children under 16 years of age without legally required affirmative authorization. If you believe that your child has provided us with information, please Contact Us.
f. Retention of personal information.
We take the protection of your personal information seriously, and have security measures, controls and policies in place. We will hold your personal information on our systems for the longest of the following periods: (a) as long as is necessary for the relevant activity or as long as is set out in any relevant agreement you enter into with us; (b) the length of time it is reasonable to keep records to demonstrate compliance with professional or legal obligations; (c) any retention period that is required by law; or (d) the end of the period in which litigation or investigations might arise in respect of your use of our Website and/or the Services that we provide to you.
