This Privacy Policy was last updated effective May 24, 2018
We are Brian Batt (“elearningfreak.com”) of 11205 Katie Beth Circle, Oklahoma City, OK 73170, USA. All references to “we”, “us”, or “our” shall be construed to mean elearningfreak.com.
When We Act as Controller and Processor
elearningfreak.com will be acting as the “Controller” of the personal data you provide directly to us via a “Contact Us” form, when creating an account, or via other contact methods. You are not required to provide your personal information for purposes of navigating through the public areas of our website.
If you are an employee or an authorized user of one of our customers which have entered into an agreement with us for the provision of our products or services, we will be acting as the “Processor” of your personal data transmitted by our customer. Our customer will be acting as Controller of your information. As processor, we do not own, control, or direct the use of any data provided to us by our customers which act as Controllers.
Personally Identifiable Information
“Personally Identifiable Information” (or “PII”) refers to contact information that directly or indirectly tells specifically who you are, such as your name, phone number, company name, job, email, postal address, or any other information that could be linked to you with reasonable effort. We do not collect sensitive information such as location information (GPS), racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation.
Passively or Automatically Collected Data
Passively or automatically collected data (referred to as “Usage Data”) is collected as you use this website. We, our affiliated entities, and our marketing partners may use automated means to collect various types of information about you, your computer or other device used to access this site, its services, related Web applications, and downloadable software. This information is based on your usage of this site and may be based on your visitation to other websites. Usage Data is essentially anonymous when collected, but could be used indirectly to identify a person.
Why We Need Your Data
We need to know the PII you provide to us directly in our capacity as controller for purposes of responding to your inquiry on our Contact Us web page and other contact methods. In addition, we need to know your PII to send you emails for other specific purposes and for sharing your PII for purposes as described in the Information Sharing and Disclosure section below. We also need to know the PII of authorized users of our customers when we act in our capacity as processor for purposes of managing the authorized use of our services.
How We Collect and Use Your Data
elearningfreak.com collects PII directly from you when you make an inquiry for an email reply on our “Contact Us” web page and other contact methods, and when you request that we send you emails. Before collecting your PII, you will have the option to give or withhold your consent for our sending you emails including our use of your PII for marketing emails to promote our products or products similar to our products or services. You may withdraw your consent at any time by unsubscribing to our emails by using an opt-out link contained in every non-transactional email or you can contact us at any time via the CONTACT US section below.
elearningfreak.com uses third-party applications to add firmographic information to the data we collect from you. This data enhancement allows us to provide more helpful, personalized communication.
We collect Usage Data as described above and with “cookies”. For additional information and how to set your browser to refuse to accept “cookies”, see the “COOKIES” section below.
We may make full, unrestricted use of Usage Data for any purpose in our sole discretion, including without limitation, to customize re-marketing ads, offers and content made available to you based on your visits to and/or usage of this site or its services, and to analyze the performance of those ads, offers and content, as well as your interaction with them.
Subject to your right to opt-out, we may combine Usage Data with PII that we collect, and use the combined data to create profiles about you only for purposes of improving our products and services and your user experience with our products and services.
How Long We Keep Your Data
We will not retain your PII for longer than required. This means that we will keep your PII for any or a combination of time periods described as follows: (i) for as long as required by law, (ii) until we no longer have a valid reason for keeping it, (iii) until you request us to stop using it, or (iv) for so long as our customer for which you are an authorized user remains a customer.
Information Sharing and Disclosure
General Disclosure Policy. We may share and disclose your PII as described below. We may share and disclose Usage Data without restriction, including without limitation, as described below. Please contact us at support@elearningfreak.com to opt out of all information sharing with a third party.
Affiliated Entities. We may provide your PII and Usage Data to any affiliated entities we may have, including our subsidiaries. Affiliated entities are entities that we legally control (by voting rights) or that control us.
Sub-Processors. We may provide access to your PII and Usage Data to our trusted sub-processors that assist us with the operation and maintenance of this site. For example, we may contract with third parties to process payments, host our servers, provide security, and provide production, fulfillment, optimization, analytics, reporting, and software maintenance and development services. In addition, our sub-processors will be given access to your information only as is reasonably necessary to provide the services for which they are contracted.
Successors. If we sell or otherwise transfer part or all of our business or assets to another organization, such as in the course of an acquisition, merger, bankruptcy or liquidation, we may transfer your PII and Usage Data. In such an event, we will require the buyer or transferee to agree to our commitments provided in this Privacy Policy.
Compelling Obligations. Except for sharing your information as described in this Information Sharing and Disclosure Section, we will not disclose information about you or the contents of your communications unless compelled to do so in the good-faith belief that such action is reasonably necessary (a) to comply with the law; (b) to comply with legal process; (c) to enforce these terms and conditions; (d) to respond to claims that any content violates the rights of third parties; (e) to facilitate the terms of an acquisition of us by, or merger with, another company, or (f) to protect our interests regarding its property, including without limitation its intellectual property.
Authorized Resellers. We may share your PII and Usage Data with our authorized resellers and partners so that they can provide customers with timely, helpful information about our products and services. Our resellers are contractually obligated to abide by the elearningfreak.com privacy policy, preventing them from sharing your information with any other third parties. Several of our resellers are located in the EU; however, we have determined that our authorized resellers all have suitable safeguards to protect your information. For more information regarding our authorized resellers and their safeguards, request descriptions via our CONTACT US section below.
Marketing Partners for Purposes of Re-Marketing. We may share your information with 3rd party vendors for purposes of re-marketing. For a description of re-marketing and your opt-out rights, see the RE-MARKETING section below.
Your California Privacy Rights. Under California Law SB 27, California residents have the right to receive, once a year, information about third parties with whom we have shared information about you or your family for their marketing purposes during the previous calendar year, and a description of the categories of personal information shared. To make such a request, please send an email to the email address provided in our contact information below and include the phrase “California Privacy Request” in the subject line, the domain name of the Web site you are inquiring about, along with your name, address and email address. We will respond to you within thirty days of receiving such a request.
Cookies and Opt-Out Procedures
We may automatically collect Usage Data through the use of “cookies.” Cookies are small text files a website uses to recognize repeat users, facilitate the user’s ongoing access to the site, and facilitate the use of the site. “Cookies” also allow a site to track usage behavior and compile site-usage information that will allow for the improvement of content.
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Remarketing
elearningfreak.com uses 3rd party vendor remarketing tracking cookies and pixels, including the Google Adwords tracking cookie. This means we will continue to show ads to you across the internet, specifically on the Google Content Network (GCN). The third-party vendors, including Google, will place cookies on web browsers in order to serve ads based on past visits to our website. This allows us to make special offers and continue to market our products to those who have shown interest in them. We do not remarket to users in the European Union.
You may opt-out of Google’s use of cookies by visiting the Ads Preferences Manager. Also, you can opt out of other third-party use of cookies by visiting the Network Advertising Initiative opt-out page.
Analytics
We may participate with third party analytics partners to monitor and analyze Web traffic and to keep track of user behavior on this site.
Google Analytics (Google) – Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the data collected to track and examine the use of this site, to prepare reports on its activities, and to share them with other Google services.
Information collected: cookie and Usage Data. Visit Privacy Policy at https://www.google.com/intl/en/policies. You may opt-out of the Google Analytics service with the Google’s Browser Add-on that’s available at https://tools.google.com/dlpage/gaoptout.
Your Rights
Use the CONTACT US section below for purposes of inquiring about your rights.
You may contact us to find out if we are processing your PII. If we are, you can ask us what Personally Identifiable Information of yours we hold and what we do with your data. If you would like, we can also provide you (or, where technically feasible, your chosen third party) with a copy of any PII that we hold about you, subject to a fee specified by law (not to exceed the reproduction cost of such document).
We may decline a request for access to or correction of PII in circumstances prescribed by the Privacy Act 1988 (Cth) (Australia), and if we do, we will provide you with a written notice that sets out the reasons for the refusal (unless it would be unreasonable to provide those reasons) and the mechanisms available to you to make a complaint.
In addition, you may: (i) request access to and rectification or erasure of your PII, (ii) request restriction of processing your PII, and (iii) withdraw your consent at any time. If you provide a notice to us regarding your exercise any of the above rights, we will forward your notice to other authorized parties which are holding and processing your PII, where appropriate.
Children’s Online Policy
We are committed to preserving online privacy for all of its website visitors, including children. This site is a general audience site. Consistent with the Children’s Online Privacy Protection Act (COPPA), we will not knowingly collect any information from, or sell to, children under the age of 13. If you are a parent or guardian who has discovered that your child under the age of 13 has submitted his or her personally identifiable information without your permission or consent, we will remove the information from our active list, at your request. To request the removal of your child’s information, please contact our site as provided below under “CONTACT US”, and be sure to include in your message the same login information that your child submitted.
Links to Other Websites
This site may contain links to other websites operated by our joint venture marketing partners. If you do click on any of the links to their websites or accept any of their promotional offers, your click-through information and any information that you provide in the process of registration or purchase will be transferred to these sites. We have no responsibility or liability for the policies and practices of these sites. You should be careful to review any privacy policies posted on any of these sites before providing information to them.
International Transfers
If you are from outside the U.S., understand that you are sending PII and Usage Data to the United States where our servers are located. That information may be then transferred within the U.S. or back out of the U.S. to other countries outside of your country of residence. Except for the U.S. and our certification for the Privacy Shield, these countries many not necessarily have data protection laws as comprehensive or protective as those in your country of residence; however, our collection, storage, and use of your PII and Usage Data will at all times be governed by this Privacy Policy.
Do Not Track Requests
Some Web browsers incorporate a “Do Not Track” feature that signals to websites that you visit that you do not want to have your online activity tracked. Each browser communicates “Do Not Track” signals to websites differently, making it unworkable to honor each and every request correctly. In order to alleviate any communication error between browsers and website, we do not respond to “Do Not Track” signals at this time. As the technology and communication between browser and website improves, we will reevaluate the ability to honor “Do Not Track” signals and may make changes to our policy.
EU Users’ Rights.
This section of our Privacy Policy applies to the users of our platform in EU. We would like to inform you about your GDPR rights and how we safeguard them.
a. Your GDPR rights to be informed, to access, rectify, erase or restrict the processing of your personal information. Our Privacy Policy enumerates the types of personal (and other) data we collect about our users in Section ‘How We Collect and Use Your Data’ above. You have the right to obtain free information about what personal data we have obtained about you, where it is stored, for how long, for what purposes it is used, to whom it was disclosed. You have the right to have us, without undue delay, rectify of inaccurate personal data concerning you. That means you can request we change your personal data in our records, or have you incomplete personal data completed. You have the “right to be forgotten,” i.e. to have us delete your personal information, without undue delay, if the data is no longer necessary in relation to the purposes for which it was collected. However, GDPR gives us the right to refuse erasure if we can demonstrate compelling legitimate grounds for keeping it.
b. GDPR gives you the right to restrict processing if any of the following applies:
i. If you contest the accuracy of your personal data, we will restrict processing it for a period enabling us to verify its accuracy.
ii. The processing is unlawful and you oppose its erasure and request instead the restriction of its use.
iii. We no longer need your personal data for the purposes of the processing, but you require us to restrict processing for the establishment, exercise or defence of legal claims.
iv. You have objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether our legitimate grounds override yours.
c. Right to data portability. Upon request, we will provide you your personal data in our possession, in a structured, commonly used and machine-readable format. You have the right to transmit that data to another controller if doing so does not adversely affect the rights and freedoms of others.
d. Right to object. You can object, on grounds relating your particular situation, at any time, to processing of your personal information, if based on point (e) or (f) of Article 6(1) of the GDPR. We will then have to stop processing, unless we can demonstrate compelling legitimate grounds for the processing. If you object to the processing for direct marketing purposes, we will have to stop processing for these purposes.
e. Right to withdraw consent. GDPR grants you the right to withdraw your erlier given consent, if any, to processing of your personal data at any time.
f. Rights related to automated decision making. As a responsible business, we do not rely on any automated decision making, such as profiling.
How to exercise your GDPR rights?
If you need to contact us in order to exercise or discuss any of your GDPR rights under this Privacy Policy, you can contact our Data Protection Officer, Brian Batt, at the CONTACT US section below.
Inquiries and Complaints
If you have any inquiries or complaints about our use of your PII, please let us know. You can contact us at any time via the CONTACT US section below, and we will take reasonable steps to investigate the complaint and respond to you.
You can also contact your national data protection supervisory authority in order to lodge a complaint against us.
Contact Us
Contact us, as follows.
Brian Batt
elearningfreak.com
11205 Katie Beth Circle
Oklahoma City, OK 73170
support@elearningfreak.com
Material Modifications Since May 24, 2018: updates effective May 24, 2018 for purposes of compliance with the EU General Data Protection Regulation.
