Privacy Policy

Privacy Policy

We at Refresh Kid LLC (collectively with any subsidiaries, “Refresh Kid”) have created this Privacy Policy to describe our practices globally regarding information we collect through our website, mobile features, and any other interactive features or services owned or controlled by Refresh Kid (each, a "Service" and collectively, the "Services"), as well as any information we collect offline and combine in our databases. Refresh Kid are the data Controller of your personal data and can be contacted at the contact details given at the end of this Privacy Policy.

Certain features discussed in this Privacy Policy may not be offered on each Service at any particular time or may not be available in certain regions.

Note that we combine and process the information we collect through all of our websites, mobile applications, and other Services in accordance with the terms set out in this Privacy Policy.

SCOPE

This Privacy Policy applies to personal information processed by us in our business globally through our Services.

1.      PERSONAL INFORMATION WE COLLECT.

The categories of personal information we collect depend on whether you are user or visitor, and the requirements of applicable law.

Information You Provide to Us.

Account Creation.

When you create a user account, we collect your name, email address, password and we may ask you to optionally (or not optionally) provide demographic or other information such as your school, school district, time zone, gender, age or birthdate, zip or postal code, and information about your interests and preferences.  

Profile Creation.

You may have the opportunity to create a profile which may include photographs, information about your academic and work history, and your interests and activities.

Your Communications with Us.

We collect personal information from you such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter, request customer or technical support, apply for a job, or otherwise communicate with us.

Communications with Others on Our Platforms.

The Services may allow community members to communicate and collaborate with each other, including some Services that allow community members to engage in one-on-one communication using a video chat or text chat feature. Our servers may record, and we may retain records of the content of any such user-to-user communications.

Payment and Financial Information.

We will process your payment information if you purchase products or services through our Services. Note that we do not store payment credit or debit card numbers.

If you utilize the Services in a way that necessitates payment from Refresh Kid to you (such as offering services for sale through Refresh Kid or participating in research projects), we may collect additional information from you, such as your bank account information, social security number, social insurance number, or taxpayer identification number, as necessary to facilitate payment and to comply with related legal obligations.

Surveys.

We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.

Social Media Content.

We may offer forums, blogs, or social media pages which you are free to participate in at your own discretion. Any content you provide on these channels will be “public” and therefore can be seen by other users. 

Information Collected Automatically or From Others.

Automatic Data Collection.

We may collect certain information automatically when you use the Services including your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet or mobile service provider, pages that you visit before, during, and after using the Services, information about the links you click, and other information about how you use the Services, including information collected from interactive services (including our e-Reader), such as notes you take and engagement during study sessions.

In addition, we may automatically collect data regarding your use of our Services, such as the types of content you interact with and the frequency and duration of your activities.

Cookie policy

We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us and our partners to record certain pieces of information whenever you visit or interact with our Services.

For users located in the EEA or United Kingdom, your consent is required before setting any cookies that are not strictly necessary on your device. You can also adjust the cookie settings on your browser.  

Third Party Technologies.

Third party cookies are set by someone other than the website you are actually visiting. We may use third party cookies to provide services and evaluate the use of the website.

We use the following types of Technologies: 

·        Cookies.

Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly. Session cookies are stored only for the time you are using the website and are deleted when you close your browser, whereas permanent cookies are stored on your device for a certain period or until you manually remove them.

·         Pixel Tags/Web Beacons.

A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.

·         Embedded Scripts.

Embedded scripts are programming code designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your computer or other device from our server or a third-party service provider and is deactivated or deleted when you disconnect from the Services.

·         Flash & HTML5.

We use Local Storage Objects (“LSOs”) such as HTML5 to store content, information, and preferences. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your web browsing activity use LSOs such as HTML 5 & Flash to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs.

Our uses of these Technologies fall into the following general categories:

·         Strictly necessary.

These cookies are strictly necessary to provide you with services available through our Websites and to use some of its features, such as access to secure areas. These include cookies that ensure security, prevent fraud, and debug where your data can be used to monitor for and prevent fraudulent activity, and ensure systems and processes work properly and securely and that technically deliver ads or content so your device can receive and send information that allows you to see and interact with ads and content.

·         Store and/or access information on a device.

Cookies, device identifiers, or other information can be stored or accessed on your device for the purposes presented to you.

·         Personalized ads and ad measurement.

Ads can be shown to you based on the content you are viewing, the app you are using, your approximate location, or your device type. A profile can be built about you and your interests to show you personalized ads that are relevant to you. The performance and effectiveness of ads that you see or interact with can be measured.

·         Personalized content, content measurement, audience insights, and product development.

A profile can be built about you and your interests to show you personalized content that is relevant to you. The performance and effectiveness of content that you see or interact with can be measured. Market research can be used to learn more about the audiences who visit sites/apps and view ads. Your data can be used to improve existing systems and software, and to develop new products.

·         Precise geolocation data, and identification through device scanning.

Data from offline data sources can be combined with your online activity in support of one or more purposes. Different devices can be determined as belonging to you or your household in support of one or more purposes.

Information from Other Sources.

We may obtain information about you from other sources, including through third-party services and organizations to supplement information provided by you. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site or you log in to a third party’s service using your Refresh Kid credentials, we may collect information about you from that third-party application that you have made public via your privacy settings. Information we collect through these services may include your name, your user identification number, your user name, location, gender, birth date, email address or other contact information, profile picture, activities such as test completion and results, and your contacts stored in that service. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services.

Analytics.

We may also use Google Analytics and other service providers to collect information regarding visitor behavior and visitor demographics on our Services.

HOW WE USE YOUR INFORMATION.

We use your information for a variety of business purposes, including to:

v  Fulfil our contract with you and provide you with our Services, such as:

·         Managing your information and accounts;

·         Providing access to certain areas, functionalities, and features of our Services including providing access to eBooks;

·         Support the shipping, tracking, and recovery of your orders (such as textbooks) and/or other products;

·         Communicating with you about your account, activities on our Services and policy changes;

·         Undertaking activities to verify or maintain the quality or safety of a service or device;

·         Processing your financial information and other payment methods for products or Services purchased;

·         Processing transactions and applications; and

·         Allowing you to register for events.

v  Analyze and improve our Services pursuant to our legitimate interest, such as:

·         Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;

·         Measuring interest and engagement in our Services and short-term, transient use, such as contextual customization of ads;

·         Undertaking research for technological development and demonstration;

·         Researching and developing products, services, marketing or security procedures to improve their performance, resilience, reliability, or efficiency;

·         Improving, upgrading, or enhancing our Services or device;

·         Developing new products and Services;

·         Ensuring internal quality control;

·         Verifying your identity and preventing fraud;

·         Debugging to identify and repair errors that impair existing intended functionality;

·         Enforcing our terms and policies (including the Honor Code); and

·         Furnishing you with customized materials about offers, products, and services that may be of interest, including new content or Services. 

v  Comply with our legal obligations, for example auditing relating to interactions, transactions, and other compliance activities.

v  Protect your vital interest or as may be required for the public good. 

Other purposes you may consent to, are notified of, or are disclosed when you provide personal information.

Automated profiling.

We may use technologies considered automated decision making or profiling. We will not make automated decisions about you that would significantly affect you, unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to use such technology. You may escalate any concerns you have by contacting us below. 

Use De-identified and Aggregated Information.

We may use personal information and other data about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create.

Testimonials.

We display personal testimonials of satisfied customers on our Services in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at support@refreshkid.com.

Cross-Device Tracking.

Your browsing activity may be tracked across different websites and different devices or apps. For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your laptop. To do this our technology partners may share data, such as your browsing patterns, geo-location, and device identifiers, and will match the information of the browser and devices that appear to be used by the same person.

Notice Regarding Third-Party Websites.

The Services may contain links to other websites, and other websites may reference or link to our website or other Services. These other websites are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

Social Media and Other Publicly Accessible Forums.

Our Services may include publicly accessible blogs, forums, social media pages, and private messaging features. By using such Services, you assume the risk that the personal information provided by you may be viewed and used by third parties for any number of purposes. In addition, social media buttons such as Facebook, Instagram, YouTube, Twitter, Pinterest, and LinkedIn (that might include widgets such as the “share this” button or other interactive mini-programs) may be on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a third party or hosted directly on our site. Your interactions with these features apart from your visit to our site are governed by the privacy policy of the company providing it.

APIs and SDKs.

We may use third-party application programming interface (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties including analytics and advertising partners to collect your personal information for various purposes including to provide analytics services and content that is more relevant to you. For more information about our use of APIs and SDKs, please contact us as set forth below.

2.      DISCLOSING YOUR INFORMATION TO THIRD PARTIES.

Except as provided below, we do not share/disclose/sell your personal information. If relevant for your jurisdiction, for lists of categories of personal information disclosed for a business purpose or sold in the last 12 months, please see below.

We do not share your Personal Information with third parties for their marketing purposes without your consent.

We may share non-Personal Information (such as aggregate user statistics, de-identified information, demographic information such as gender, age, graduation years, and other scholastic-related information), and Usage Information with third parties, including advertisers, content providers, and analytics providers; and third parties may collect non-Personal Information when you visit the Services.

When You Request That We Share Your Information.

We may offer opportunities and features through the Services that are brought to you by a third party or that otherwise involve sharing your information with a third party. If you request, direct us or agree at that time to have your information shared, your information will be disclosed to that third party (or parties) and will be subject to the privacy policy and practices of that third party. This includes, without limitation, instances in which you use our Services to purchase products or services provided, in whole or part, by third parties. You also may request, sometimes through your use of an interactive feature or social media feature, that we share information about you with a third party or publicly.

Contests and Promotions.

We may offer contests and other promotions ("Promotion") that may require registration. By participating in a Promotion, you are agreeing to governing terms, conditions, or official rules, which may contain specific requirements of you, including allowing the sponsor(s) of the Promotion to use your name, voice, likeness, or other indicia of persona in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, Personal Information, such as your name and shipping address, may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion's official rules, such as on a winners list.

Service Providers.

We may share any personal information we collect about you with our third-party service providers. The categories of service providers to whom we entrust personal information include: IT and related services; payment processors; customer service providers; fraud detection and prevention providers, security and risk management providers, and other vendors to support the provision of the Services. For details of the current third parties we use, please contact us to find out more. 

Business Partners.

We may provide personal information to business partners with whom we jointly offer products or services. In such cases, our business partner’s name will appear along with ours.

Advertising Partners.

Through our Services and if your consent has been sought in accordance with our cookie policy, we may allow third-party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information (such as demographic information and past purchase history) with third-party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit the third-party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Services to share information that may be useful, relevant, valuable, or otherwise of interest to you. If you prefer not to share your personal information with third-party advertising partners, you may follow the instructions below.

Disclosures to Protect Us or Others.

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; detect or prevent fraud; or assist with an investigation or prosecution of suspected or actual illegal activity. 

Disclosure in the Event of Merger, Sale, or Other Asset Transfers.

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

International Data Transfers.

You agree that all information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States, Canada, Israel, India or other countries, which may have data protection laws that are different from the laws where you live. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. Further details can be provided upon request using the contact details below.  Please note that your personal information will be accessible to law enforcement and/or regulatory authorities according to the applicable laws of such foreign jurisdictions.