Effective Date: May 1, 2018
1. INFORMATION WE COLLECT ABOUT YOU
We collect several types of information about visitors and/or users of our Services. We may collect this information either directly when you provide it to us or automatically as you navigate through the Websites or App.
(a) We will collect and process your personal data when you register for a Service/create an account, subscribe to a newsletter, submit feedback, enter a contest, fill out a survey, or send us a communication. When ordering products or services on the Websites or App, you may also be asked to provide a credit card number and other payment-related information. Depending upon the activity, some of the information we ask you to provide is required to use the Services (e.g. registering an account) and some is voluntary. If you do not provide data when needed for a particular activity, you will not be able to engage in that activity.
We also collect your Internet Protocol (“IP”) address. We use your IP address to diagnose problems with our servers and/or software, to administer our Services, and to gather demographic information.
(c) When you download our App and use our Services, we automatically collect information on the type of device you use and the operating system version, so we know the best version of the application to provide you. We do not ask you for, access, or track any location-based information from your mobile device at any time while downloading or using our App or Services.
(d) If you are a school and you use a Sagebooks service for children under the age of 16, or the equivalent minimum age in the relevant jurisdiction, you are responsible for obtaining consent from the parents/legal guardians of each child you wish to allow to participate in using any of our Services. A child using our Services will be able to participate in certain limited activities (such as taking online educational and informational courses).
2. WHERE WE STORE DATA
3. HOW WE USE YOUR INFORMATION
We use information held about you in the following ways:
To present content from our Services in an effective manner for you and for your computer or mobile device
To provide you with information, products or services that you request from us or which we feel may interest you
To carry out our obligations arising from any contracts entered into between you and us, including for billing and collection
If you pay for Services using a credit card, we will transmit your credit card data to the appropriate credit card company and/or credit card payment processing company
To allow you to participate in interactive features of our Services, when you choose to do so
To contact you about our Services
In any other way we may describe when you provide the information or when we prompt you regarding a new use of information about you.
4. DISCLOSURE OF YOUR INFORMATION
(a) We provide and support some of our Services through contractual arrangements with service providers and other third parties. We and our service providers use your personal data to operate our Websites and to deliver Services. For example, we must release your credit card information to the card-issuing bank to confirm payment for products and services purchased on our Websites; and provide order information to third parties that help us deliver the Services.
5. UPDATING OR CORRECTING YOUR PERSONAL DATA
We offer settings to control and manage the personal data we have about you, including the ability to:
Delete Data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).
Amend or Rectify Data: You can edit some of your personal data through your account. You can also ask us to amend your data in certain cases, particularly if it is inaccurate.
Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
Right to Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.
You may change your personal data associated with your account on your “My Profile” tab.
6. CANCELING YOUR ACCOUNT OR DELETING YOUR PERSONAL DATA
You may choose to close your account in which case we will delete your information, including your learning history, within 60 days of your request. However, we may retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), comply with contractual obligations (including an agreement between Sagebooks and your enterprise sponsor), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms of Service or Website Use Policy, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed. You can close your account on your “My Profile” tab.
7. CHOICES REGARDING CONTROL OF YOUR PERSONAL DATA
You can access some of the information that we collect about you. For example, by logging into your account, you can access information regarding recent orders from the Websites; certain personal data we maintain about you; your communication preferences; and your payment settings.
With respect to your communications preferences, you can unsubscribe from newsletters by following the instructions included in the newsletter you receive. If your email address has changed and you would like to continue to receive newsletters, you will need to access your account, update your email address information in your account, and sign-up again for the newsletter. Occasionally we may send out emails concerning website disruptions.
8. LAWFUL BASES FOR PROCESSING
We will only collect and process personal data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g., to deliver the Services you have requested) and “legitimate interests.”
Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you reside in the Designated Countries and have any questions about the lawful basis upon which we collect and use your personal data, please contact our Data Protection Officer at email@example.com.
9. DATA SECURITY
Access by you to your account is available through a password and/or unique username selected by you. This password is encrypted. We recommend that you do not divulge your password to anyone, that you change your password often using a combination of letters and numbers, and that you ensure you use a secure web browser. We cannot be held accountable for activity that results from your own neglect to safeguard the secrecy of your password and username. If you share a computer with anyone, you should always log out of your account after you are finished in order to prevent access to your information from subsequent users of that computer.
Please notify Customer Support as soon as possible if your username or password is compromised.
Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal data, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity and privacy of any and all information and data exchanged between you and us through this Website cannot be guaranteed and we shall have no liability to you or any third party for loss, misuse, disclosure or alteration of such information; and (c) any such information and data may be viewed or tampered with in transit by a third party.
In the unlikely event that we believe that the security of your personal data in our control may have been compromised, we will try to notify you. To the extent you have provided us with your email address, we may notify you by email and you agree to our use of email as a means of such notification. If you prefer for us to use another method to notify you in this situation, please contact Customer Support with the alternative contact information you wish to be used.
10. COOKIES AND OTHER TECHNOLOGIES
11. MOBILE ANALYTICS
We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information such as how often you use the App, the events that occur within the App, aggregated usage, performance data, and where the App was downloaded from. We do not link the information we store within the analytics software to any personal data you submit within the App.
12. DIRECT MARKETING
We currently do not share personal data with third parties for their direct marketing purposes without your permission.
14. HOW DO YOU CONTACT US WITH QUESTIONS?
Room 15, 9/F, One Midtown
11 Hoi Shing Road
Residents in Designated Countries may have additional rights under their laws.