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
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
applies to personal information processed by us in our business globally
through our Services.
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
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.
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
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.
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
Payment and Financial
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.
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.
Automatically or From Others.
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
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
We, as well as third
parties that provide content, advertising, or other functionality on the
(“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 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 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
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:
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
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
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
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.
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
We use your information
for a variety of business purposes, including to:
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
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;
Allowing you to register for events.
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
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
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.
with our legal obligations, for example auditing relating to interactions,
transactions, and other compliance activities.
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
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
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.
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 email@example.com.
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.
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
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
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.
DISCLOSING YOUR INFORMATION TO THIRD
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
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
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
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
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
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
Through our Services and
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
Disclosures to Protect Us
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.
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.