Privacy Policy

PRIVACY POLICY

Last updated: September 1, 2020

Introduction

We are committed to protecting your Personal Data and your right to privacy. The following Privacy Policy, which you access through our website, explains how we handle the information you provide. We aim to explain as clearly as possible what information we collect, how we use it, and what rights you have in relation to it.

Informed Consent

Please read this privacy policy carefully, as it will help you make informed decisions about sharing certain Personal Data with us. We need your informed consent.

IF YOU ACCESS OUR PLATFORM AS A MINOR USER, OR AS A PARENT OF A MINOR USER, PLEASE READ THE FOLLOWING FIRST:

Collection of Personal Data from Minor Users

This website or application is an educational platform. To provide our services, users must use an access code given by their authorized teacher. We do not directly collect personal data from minor users.

The academic institution, after consenting to this policy, enrolls the list of users on the platform directly, according to the grade or level of the group of users on the list.

In particular:

• We use the users’ code to track their learning path through the use of our platform. The platform has various activities with specific learning routes. As users complete these exercises, the system records their responses to provide individualized grading;
• We use this information generated by the user’s use of the system to perform our services and make our platform an understandable academic tool; and
• We also use this information generated for internal statistical purposes, study, and personalization in the educational field.

We do not collect sensitive Personal Data (special category) from minor users enrolled in our program. We do not sell or market any personal data.

Since we do not store personal data of minor users, parents have the right to:

• Be informed by the teacher about their children’s information and academic progress;
• Request the teacher to correct or update their child’s information;
• Refuse further contact from the site with their child; and
• To delete such information, contact the academic institution’s administrator.

FOR ALL USERS, PLEASE READ THE FOLLOWING:

What is this policy about?

This privacy policy governs the collection, use, and disclosure of Personal Data. It describes our practices regarding the information we collect through our websites (the “Websites”), the software applications we have available for use on computers or mobile devices (the “Applications”), and HTML-formatted email messages that we send and that link to this Privacy Policy, all owned by Integra Cloud Technologies Corp., and from which you access this document. We refer to these websites, applications, and emails in this agreement as the “Services.” Our Privacy Policy applies to users who are authorized to access the password-protected areas of the Services (“User(s)”). By providing us with Personal Data, you accept the terms and conditions of this Privacy Policy, which governs data collection and use. If you do not agree with the terms of this Privacy Policy, you cannot access or use the Services.

Who is responsible for your data?

The party responsible for your data is Integra Cloud Technologies Corp.

Why do we collect certain Personal Data?

We collect Personal Data for the following necessary purposes:

• We collect the name of the authorized User to track their learning path through the use of our platform. The platform has various activities with specific learning routes. As users complete these exercises, the system records their responses to provide individualized grading. We use this information generated by the user’s use of the system to perform our services and make our platform an understandable academic tool. Additionally, we use this information generated for internal statistical purposes, study, and personalization in the educational field;
• To administer our websites;
• To respond to any communication, inquiry, or request for information or services received from you, in the manner in which it was received;
• For internal research, studies, and investigations, and internal statistics related to our academic purpose;
• To provide the function and utility of the device/application for the authorized User;
• To monitor, maintain, and improve our services; and
• To create new services.

We will not use the Personal Data you provide in a manner inconsistent with the purposes for which you provided it, as outlined above.

What Personal Data do we collect?

“Personal Data”: are Personal Data directly related to and that identify an authorized User as an individual or relate to an identifiable person. For the purposes of providing our Services, we collect from authorized Users their name (first and last name) and their email address. As mentioned earlier, we track the learning path of the authorized User through the use of our platform. This information, resulting from the active use of our platform (e.g., responses to developed learning activities), serves to guide the academic progress of the User.

“Sensitive Personal Data”: We do not collect or process sensitive Personal Data (or special categories) from any of our authorized Users. We ask that you do not send or disclose any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometric or genetic characteristics, criminal background, or union memberships) on or through the Services or otherwise.

“Other Information”: is any information that does not reveal your specific identity or does not directly relate to an individual, such as:

• Hardware and software information, including browser, device information, IP address, and access times.
• Data on the use of services, such as progress rates, grades, and access time logs.
• Information collected through cookies, pixel tags, and other technologies.
• Demographic information such as country, postal code, age, gender, and other information provided by you.
• Contact information of the institution, such as name, email, address, phone, website, logo, and name of the coordinator, phone, and email, if you provide it to us.

The consolidated information generated by the use of our platform by authorized Users (e.g., responses provided by the user to different learning activities on the platform) may be used for internal reports and analysis by the platform. These reports, which contain such consolidated information, will be subject to industry-standard practices to minimize the likelihood of identifying any individual user and may be shared with third parties. Any transfer of consolidated information will require a review process to ensure its security.

Where are your data stored?

All data collected through or using devices within multiple countries are stored on servers primarily located in the United States of America or any other region used by Amazon Web Services (our cloud service provider), which complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. By using the Services, you agree to the transfer of information to countries outside your country of residence. In this regard, we take appropriate measures to ensure that data remains within jurisdictions with adequate protections for Personal Data and to ensure that recipients of our Personal Data are subject to confidentiality obligations, as appropriate and necessary. When this is not possible, we seek data minimization as well as the selection of reliable companies with privacy policies and auditable processes that we have reviewed and seek to ensure that adequate security measures are in place to protect the transferred data.

How do we collect your Personal Data?

We collect Personal Data from authorized users in the following ways:

• Through the Services: We collect Personal Data through the Services, for example, when you, or the academic institution that enrolls Users in our program, create an account or fill out your profile.
• Offline: We may collect Personal Data from you offline, such as when you contact customer service. Please note that if you disclose personally identifiable information or sensitive Personal Data directly through our public message boards, this information may be collected and used by others.

How do we collect Other Information?

We may collect Other Information in various ways, including:

• Through your browser or device: Most browsers or devices collect certain information automatically, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, internet browser type and version, and the name and version of the Services (such as the Application) you are using. We use this information to ensure that the Services function properly.
• Through the use of the application: When you download and use it, we track and collect application usage data, such as the date and time the application accesses our servers and the information that has been downloaded to the application according to your device number.
• Use of cookies: Cookies are pieces of information stored directly on the computer you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other anonymous traffic data. We use the information solely to support the internal operations of the Services, such as security purposes, to facilitate navigation, display information more effectively, personalize your experience while using the Services, and recognize your computer to help you use the services. We also collect statistical information on the use of the Services to continuously improve their design and functionality, understand how they are used, and help us resolve your inquiries. If you do not want information to be collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically reject cookies or have the option to reject or accept the transfer of a particular cookie (or cookies) to your computer from a specific site. You may also consult this link. However, if you do not accept cookies, you may experience some inconvenience in using the Services. For example, we may not recognize your computer, and you may need to log in each time you visit our website.
• Use of pixels and other similar technologies: Pixels (also known as web beacons and invisible GIFs) may be used in connection with some Services to, among other things, track the actions of users of the Services (including authorized Users who may receive email messages from us) and collect statistics on the use of the Services and response rates.
• Analytics: We use third parties, including Google Analytics, who use cookies and similar technologies to collect and analyze information about the use of the Services and report on activities and trends. You can obtain information about Google’s practices at this link and opt-out by downloading the Google Analytics opt-out browser add-on at this link.
• IP Address: Your IP address is a number that is automatically assigned to the computer you are using by your Internet Service Provider (ISP). An IP address can be identified and automatically recorded in our server log files whenever a user accesses the Services, along with the time of the visit and the pages visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications, and other services. We use IP addresses for the purpose of supporting the internal operations of the Services, such as calculating usage levels, diagnosing server problems, and administering the Services. We may also obtain your location, approximate and general, from your IP address.
• From you: Certain information, such as your communication preference, may be collected from authorized Users when they voluntarily provide it.
• By summarizing information: Aggregated Personal Data does not personally identify you or any other user of the Services.

Please note that this Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of third parties, including third parties operating any site or service to which the Services link. The inclusion of a link in the Services does not imply endorsement of the linked site or service by us or our affiliates. In addition, we are not responsible for the collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Twitter, Apple, Google, Microsoft, or any other app developer, Learning Management System (LMS) provider, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, even with respect to any Personal Data you disclose to these or other organizations.

How may we use Personal Data?

We do not sell, rent, or lease any personal data. We use Personal Data collected from authorized Users to:

• Operate the Services you have requested.
• Respond to your inquiries and fulfill your requests, such as sending you newsletters and reports on the status of the Services.
• Send you administrative information, such as information about the Services and changes to our terms, conditions, and policies.
• Inform you of other products or services available.
• Contact you via surveys to conduct research about your opinion of current services or potential new services that may be offered.
• Allow you to participate in contests.
• Personalize your experience on the Services by presenting personalized content and advertising.
• For our internal business purposes, such as data analysis, audits, monitoring and preventing fraud, developing new products, enhancing, improving, or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns, and operating and expanding our business activities.

We may occasionally contact you on behalf of external business partners about a particular offer that may be of interest to you. In those cases, your unique personally identifiable information is not transferred to third parties.

How may Personal Data be disclosed?

Personal Data may be disclosed:

• To the authorized User or an academic institution that enrolls users in our program, upon request.
• To our service providers, who provide services such as website hosting, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.
• By you, on profile pages and other services where you can post information and materials. Please note that any information you post or disclose through these services will become public and may be available to other users and the general public. We urge you to be very careful when deciding to disclose information on other services.
• To a third party, in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or part of our business, assets, or shares (including in connection with any bankruptcy or similar proceedings).
• As we deem necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) and, in the unlikely event that having such data (a User’s name) would pose a risk to the Company or its affiliates, and it is deemed necessary to disclose it to an authority or to be used as evidence in certain legal proceedings.

How may we use and disclose Other Information?

We may use and disclose Other Information for the purposes mentioned above, except when we are required to do otherwise under applicable law. In some cases, we may combine Other Information with Personal Data. If we do so, we will treat the combined information as Personal Data as long as it remains combined.

How do we protect Personal Data?

We seek to use reasonable organizational, technical, and administrative measures to protect Personal Data within our organization. As you know, unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. However, we work with a commitment to ensuring that data is encrypted while in transit, and access to this data will be strictly limited to a minimum number of people and subject to confidentiality commitments. Additionally, we employ security measures such as using firewalls to protect against intruders, creating redundancies in our networks, and testing and protecting against network vulnerabilities. When Personal Data is transmitted to other websites, it is protected through the use of HTTPS encryption, such as the Secure Socket Layer (SSL) protocol. Access controls within the organization limit who can access information. If you have reason to believe that your interaction with us is no longer secure (for example, if you believe your account security has been compromised), please notify us immediately in accordance with the “How to Contact Us” section below.

How long do we retain Personal Data?

We will retain your Personal Data for the period necessary to fulfill the purposes described in this Privacy Policy unless a longer retention period is required or permitted by law.

What are your choices regarding marketing-related communications?

You may opt out of receiving emails and notifications about the status of the Services and marketing related to us at any time by clicking on the unsubscribe link in such an email. Additionally, in the user settings, you can opt out of receiving notifications. We will try to comply with your requests as soon as reasonably possible. Please note that if you do not wish to receive our marketing-related emails and communications, we may still send you important administrative messages, which you cannot opt out of receiving. You can always withdraw the consent given to this Policy. To do so, please notify us in accordance with the “How to Contact Us” section below.

How can you access, change, or delete your Personal Data?

If you are an authorized User and would like to review, correct, update, suppress, or delete the Personal Data you have previously provided about yourself or others, please notify us in accordance with the “How to Contact Us” section below. In your request, make it clear what Personal Data you would like to change, and whether you would like your Personal Data to be removed from our database. For your protection, we can only implement requests regarding the Personal Data associated with the particular email address you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your requests as soon as reasonably possible. Please note that we may need to retain certain information for record-keeping purposes. There may also be residual information that will remain in our databases and other records, which will not be deleted.

How to Contact Us

If you have any questions about this Privacy Policy, please contact us at legal@integracloud.tech. Because email communications are not always secure, please do not include sensitive information in your emails. All communications with our company are free of charge in relation to the terms of this Policy.

Updates to this Privacy Policy

We may change this Privacy Policy. The “LAST UPDATED” legend at the top indicates when this Privacy Policy was last revised. Any changes will take effect when we post the updated Privacy Policy for the Services, and you provide your consent. We encourage you to periodically review this Privacy Policy to stay informed of any updates.