PRIVACY AND COOKIES POLICY

Effective Date: December 16, 2022

Welcome to the Light Blue Learning, Inc. (referred to as "Light Blue Learning,” "we" or "us") website at LightBlueLearning.com (including all content under the "LightBlueLearning.com" domain name, and referred to herein as the "Website"). This notice ("Privacy Policy") supplements and is included as a part of our Website Terms of Service.   By accepting the Website Terms of Service, you also agree to this Privacy Policy.

This Privacy Policy explains our online information collection and use practices, and the choices you can make about the way we use such information. This website is designed to assist teachers with individualized strategies to assist in student instruction (the “Services”), including access to proprietary information and materials (the “Materials”).  As such, we collect information necessary to provide the Services.  Please take the time to read and understand this Privacy Policy so that you can appreciate how we use your Personal Data (as defined below). AS WE UPDATE THE WEBSITE OR EXPAND OUR SERVICES, WE MAY CHANGE THIS PRIVACY POLICY UPON NOTICE TO YOU, HOWEVER, PLEASE REVIEW IT FROM TIME TO TIME.

This Privacy Policy is subject to the provisions of applicable data protection and privacy laws.

“Personal Data” in this Privacy Policy means any information relating to you as a natural person that can be directly or indirectly related to you, a student, or a student’s parent or legal guardian.  Personal Data generally includes name, email address, ID number, location, household information, online ID, and factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity. Your Personal Data may identify you as a person, and thus is often referred to as Personally Identifiable Information ("PII") or Personal Information (“PI”).  Both PII and PI are included in the term “Personal Data” as used in this Privacy Policy.

1.       Who Collects Your Information On Our Website?

We do. We collect information from you on the Website, and we are responsible for protection of your information.

2.       What Information Does Light Blue Learning Collect?

A.     Requested Information.  On various pages on the Website, we may request specific Personal Data about you in order to register you for an account to use our Services and Materials, add you to our email and text lists, facilitate payments for and delivery of our Services and Materials, or fulfil your requests for information. You may choose not to provide your or your student’s or your student’s parent or legal guardian’s Personal Data, but then you will not be able to take advantage of some of the features of our Website and Services. We only collect basic Personal Data about you that does not include any special category data (e.g., race, ethnicity, health-related). Nor do we collect any information about criminal convictions and offenses.

The types of Personal Data we collect and save include:

●      Contact and account registration information such as name, work email address, school physical address including zip code, and phone number;

●      Financial and transactional information such as bank or credit card information;

●      Information that you provide in using our Services, such as the following information provided by the Teacher through the use of the Services:

o   About the Teachers:

▪       First and last name

▪       Teacher’s school and school zip code

▪       Work email address

▪       Phone number

o   About the Students:

▪       First and last name

▪       Student grade/age range

o   About the Student’s Parents or Legal Guardians:

▪       First and last name

▪       Email address

●      Marketing and Communications Data including your email address, your preferences in receiving marketing materials from us, and your communication preferences;

●      Information you provide such as behavioral issues, feedback, comments or other messages provided to us or to others (teachers, parents, legal guardians) while using the website; and

●      Technical and usage information collected in our logs.  Such information may include standard web log entries that contain your IP address, page URL, browser plug-in types and versions, device information and identifier, operating system information, and timestamp.

B.     Aggregate Information.  We may also collect anonymous, non-identifying and aggregate information such as the type of browser you are using, device type, the operating system you are using, and the domain name of your Internet service provider. Aggregated data may be derived from your Personal Data but is not itself Personal Data and it cannot be used, either on its own or together with other data, to directly or indirectly reveal your identity.

3.       Why Is My Personal Data Being Collected?

We need to collect your Personal Data so that we can provide the Services to you.  We also collect aggregate information to help us better design the Website. We collect log information for monitoring purposes to help us to diagnose problems with our servers, administer the Website, calculate usage levels, and otherwise provide services to you.

4.       How Do We Use the Information We Collect?

A.     We use the Personal Data you provide for the purposes for which you have submitted it including:

●      Responding To Your Inquiries, Feedback and Fulfilling Your Requests.  We may use your Personal Data to organize Services and Materials, respond to your inquiries and feedback, and to fulfil your requests for information.

●      Creating and Maintaining Your User Account.  We use your Personal Data to create and maintain an account for you to allow you to use the Services and Materials we make available on the Website.

●      Purchasing Goods. We process your payment details as part of our Services so that you can access the Services and Materials. We do this through use of tokens that represent (but do not contain) your financial information.

●      Participating in Special Promotions.

●      Communicating With You About Our Services.  We may use your Personal Data to send you marketing information about new Services and other items that may be of interest to you.

●      Sending Administrative Emails and Texts.  We may use your Personal Data to send you emails or texts to: (a) confirm your account and your other Personal Data, (b) organize the Services and provide Materials and other information about the Services, (c) provide you with information regarding the Website, or (d) inform you of changes to this Privacy Policy, our Terms of Service, or our other policies.

B.     We may use anonymous aggregated information that we collect to improve the design and content of our Website, and to enable us to personalize your Internet experience.  We also may use this anonymous aggregated information to analyze how our Website is used, analyze industry trends, as well as to enable us to offer new programs or services.

5.       What Are Your Choices Regarding Our Marketing Materials?

We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. We will obtain your consent with regard to sending you marketing and advertising materials per state and national requirements.       In general, we will provide a button, checkbox or other means where you affirmatively opt-in to receive marketing emails or other communications from us.  You can change your preferences or ask us to stop sending you marketing messages and/or remove your email from our mailing lists by contacting us at therese@LightBlueLearning.com or by following the instructions within the marketing messages that you have received.

6.       Do We Share Your Personal Data?

We do not sell your Personal Data to any third parties.  Also we will not share your Personal Data except:

(a) for the purposes for which you provided it;

(b) with your consent;

(c) as may be required by law, for example with our professional advisors, lawyers, insurers, regulators and other authorities, or as we think necessary to protect our organization or others from injury (e.g., in response to a court order or subpoena, in response to a law enforcement agency request, or when we believe that someone is causing, or is about to cause, injury to or interference with the rights or property of another);

(d) on a confidential basis with persons or organizations with whom we contract, such as our suppliers, to carry out internal site operations or as necessary to render the Services; or

(e) with our business partners only in compliance with relevant data protection laws.

 

We may also share aggregate anonymous information with others, including affiliated and non-affiliated organizations. 

Finally, we may transfer your Personal Data to our successor-in-interest in the event of an acquisition, sale, merger or bankruptcy. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this Privacy Policy.

7.       What Categories of Personal Data Do We Share?

We share only the categories of Personal Data required for us to carry out our internal site operations or as necessary to render our Services that you have requested.  These categories include your contact and registration information, financial and transaction information, information you process through our Services, and your technical and usage information.  As discussed above, the categories of third parties with whom we may share such Personal Data include our service providers, suppliers, business partners, and professional advisors, as well as law enforcement.

8.       Are There Other Ways My Personal Data Could Be Shared?

You may elect to share certain Personal Data with individuals or with the public via your use of the Website. For example, we may provide links on the Website that may make it possible for you to publicly share information via social media such as Facebook, Instagram or Twitter. In this case, you will control such sharing.  Be aware that when you choose to share any information online with anyone, including friends, public officials, or the public at large, you may be disclosing sensitive information, or information from which sensitive information can be inferred.  Always use caution when sharing information through the Website. You understand and agree that Light Blue Learning is not responsible for any consequences of your sharing of information through and beyond the Website. We do not control Facebook, Instagram or Twitter or any other third-party websites and are not responsible for their privacy policies. When you leave our Website, we encourage you to read the privacy policy of every website you visit.

9.       How Can You Access and Control Your Information?

After registering for an account on the Website, you may log-in to the account and edit your Personal Data in your profile.  For instructions on how you can further access your Personal Data that we have collected, or how to correct errors or inaccuracies in such information, please send an e-mail to therese@LightBlueLearning.com.  We will also promptly stop using your Personal Data and remove it from our servers and database at any time upon your e-mail request.  To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access, making corrections or removing your information.

10.    How Do We Store and Protect Your Information?

A.     After receiving your Personal Data, we will store it on our Website systems for future use. We have physical, electronic, and managerial procedures in place to safeguard and help prevent unauthorized access, maintain data security, and reasonably use the information we collect.  Unfortunately, no data transmission over the Internet or data storage solution can ever be completely secure. As a result, although we take industry-standard steps to protect your information (e.g., strong encryption), we cannot ensure or warrant the security of any information you transmit to or receive from us or that we store on our or our service providers' systems.

B.     We store your Personal Data until you request us to remove it from our servers.  We will only retain your Personal Data for as long as is reasonably necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 

C.     We store our logs and other technical records indefinitely.

11.    Cookie Policy: How Do We Use Cookies And Other Network Technologies?

A.     To enhance your online experience with us, our Website may presently or in the future use "cookies."  Cookies are text files that our web server may place on your hard disk to store your preferences.  We may use session, persistent, first-party and third-party cookies.  Cookies, by themselves, do not tell us your e-mail address or other Personal Data unless you choose to provide this information to us. Once you choose to provide Personal Data, however, this information may be linked to the data stored in a cookie. We have summarized the types of cookies in Section 11.D, below.

B.     We or our service providers may also use "pixel tags," "web beacons," "clear GIFs" embedded links, and other commonly used information-gathering tools in connection with some Website pages and HTML-formatted email messages for such purposes as compiling aggregate statistics about Website usage and response rates.  A pixel tag is an electronic image (often a single pixel), that is ordinarily not visible to website visitors, and may be associated with cookies on visitors' hard drives. Pixel tags allow us and our service providers to count users who have visited certain pages of the Website, to deliver customized services, and to help determine the effectiveness of our Website and Services.  When used in HTML-formatted email messages, pixel tags can inform the sender of the email whether and when the email has been opened.

C.     As you use the Internet, you leave a trail of electronic information at each website you visit.  This information, which is sometimes referred to as "Visitor Data", can be collected and stored by a website's server. Visitor Data can reveal the type of computer and browsing software you use and the address of the website from which you linked to the Website.  We may use Visitor Data as a form of non-Personal Data to determine how much time visitors spend on each page of our Website, how visitors navigate through the Website, and how we may tailor our web pages to better meet the needs of visitors.  We will only use this information to improve our Website.

D.     The types of cookies that we may use on the Website include the following:

(a)       Strictly necessary cookies. These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-billing services.

(b)       Analytical/performance cookies. These cookies allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by assisting users in easily finding what they are looking for.

(c)        Functionality cookies. These cookies are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

(d)       Targeting cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed. We may use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

E.      How To Manage Cookies

You may manage, disable and remove cookies from your computer using the following methods:

(1) Modify your browser settings:

●      Please follow the instructions provided by your browser to manage, disable or remove cookies.

●      Please be careful in making your choices. By blocking the receipt of all cookies indiscriminately, including the technical ones, without providing a specific exception for the Website, you may no longer able to surf the Website or to benefit, in whole or in part, from its functionalities. Furthermore, removing the technical cookies could remove the preferences set up by using the Website so that you could no longer find products or services you expect to see.

(2) Use our interactive banner:

●      In order to disable first party profiling cookies and/or identifiers (i.e., those cookies that we directly install), you can simply edit your preferences using the interactive banner that is displayed on our Website homepage, as illustrated below. Your choice to disable the use of these cookies will not have any consequences on your ability to surf the Website or use its functionalities.  You may reinstate cookie functionality at any time.

●      By clicking “Accept” on the cookie consent box on our interactive banner when you first access our Website and by continuing to access and use our Website, you accept our use of cookies. For your reference, the wording of our cookie consent box is as follows:

We use cookies on this website to help the website operate effectively and to give you the best experience. Some of these cookies are necessary for the website to operate and others are not (but can be useful to help the website recognize you from previous visits, analyse web traffic and other functions). More information (including how to manage your cookie preferences) can be found on our Privacy Policy. Cookies that are not strictly necessary are placed on your computer only with your consent. Please click “Accept” to indicate your consent, or “Reject” if you do not wish to accept these cookies.

In order to disable any third party’s cookies or identifiers, please see the privacy policies of that third party.

12.    Collection of Information by Others

Our Website may include links that take you to certain third party websites.  Please check the privacy policies of these other websites to learn how they collect, use, store and share information that you may submit to them or that they collect.

13.    Children and Young People's Information

Other than the limited information we collect about students from the teachers that use this site (noted above in Section 2), we do not knowingly collect any information from any minors, and we comply with all applicable privacy laws including the CCPA, USA Children's Online Privacy Protection Act ("COPPA"), Family Educational Rights and Privacy Act (“FERPA”), and associated Federal Trade Commission ("FTC") rules for collecting Personal Data from minors.  Please see the FTC's website (www.ftc.gov) for more information.  If you have concerns about this Website or its Services, wish to find out if your child has accessed our Services, or wish to remove your child's Personal Data from our servers, please contact us at therese@LightBlueLearning.com.  In the event that we discover that a child under the age of 13 has provided Personal Data to us, we will make efforts to delete the child's information in accordance with the COPPA.  If you believe that your student or another child under 13 has gained access to our Website without your permission, please contact us at therese@LightBlueLearning.com.

14.    California Privacy Rights

The California Consumer Privacy Act (“CCPA”) enhances privacy rights and consumer protection for residents of California.  Under the CCPA, California residents have the rights to: 1) know what Personal Data are being collected about them in the preceding twelve (12) months; 2) know if their Personal Data are sold or disclosed in the preceding twelve (12) months, and to whom; 3) say 'no' to the sale of their Personal Data; 4) access and request deletion of their Personal Data; and 5) receive equal service and price from businesses, even after exercising the foregoing privacy rights.  California law allows California residents to request information regarding our disclosures in the preceding twelve (12) months, if any, of their Personal Data to third parties. Further, in accordance with the CCPA we provide a specific ‘Do Not Sell My Personal Information’ link on our Website where you may specifically opt out of any sale of your Personal Data by us.  To request access or deletion of your Personal Data, please contact us at therese@LightBlueLearning.com with "Request for Privacy Information" in the subject line. Please include enough detail for us to locate your file to include your name, email address, and username, if any.  After verifying your identity, we will provide you with the requested information within forty-five (45) days of receipt. We reserve our right not to respond to requests submitted to an address other than the one posted in this notice. Please note that the CCPA law does not cover all information sharing. Our disclosure only includes information covered by the law.

15.    Changes to this Policy

Because our business needs may change over time, we reserve the right to modify this Privacy Policy.  If at any time in the future we plan to use your Personal Data in a way that differs from this Privacy Policy, we will revise this Privacy Policy as appropriate.  In the event of a change to our Privacy Policy, we will email the updated policy to the email address that you provided to us.  Your continued use of the Website following our notice of changes to this Privacy Policy means you accept such changes.

16.    Our Contact Information

If you have any questions or concerns about this Privacy Policy, please contact us via e-mail at therese@LightBlueLearning.com.

Copyright © Light Blue Learning, Inc. All rights reserved. The Website is the property of Light Blue Learning, Inc. and is protected by United States and international copyright, trademark, and other applicable laws. This includes the content, appearance, and design of the Website, as well as the trademarks, product names, graphics, logos, service names, slogans, colors, and designs.