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Privacy Policy
California Addendum

Updated February 19, 2021

This Addendum to our Privacy Policy describes our policies and procedures on the collection, use and disclosure of Your information when You use the Service, and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.


Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access our Service or parts of our Service.
  • Application means any software program provided by the Company accessed by You on any electronic device, including but not limited to a native mobile application and a SaaS web application, named Red Rover.
  • Business, for the purpose of the CCPA, refers to the Company as the legal entity that collects Personal Data and determines the purposes and means of the processing of such Personal Data, or on behalf of which such Personal Data is collected and that alone, or jointly with others, determines the purposes and means of the processing of Personal Data, that falls into the scope of the CCPA.
  • CCPA means California Consumer Privacy Act of 2018.
  • Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Red Rover Technologies LLC, 559 W Uwchlan Ave, Exton, PA 19335.
  • Consumer, for the purpose of the CCPA, means a natural person, who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
  • Country refers to the United States.
  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
  • Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
  • Google means Google Inc.
  • Personal Data is any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly to an identified or identifiable individual.
  • Privacy Policy means this privacy policy.
  • Sale, for the purpose of the CCPA, means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, Personal Data to another business or a third party for monetary or other valuable consideration.
  • Service refers to the Application.
  • Service Provider means any natural or legal person, who processes Personal Data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
  • Third-Party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
  • Usage Data refers to data, including Personal Data, collected automatically, either generated by the use of the Service from the Service infrastructure itself, or through cookies.
  • You shall mean the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

CCPA Privacy Notice

This Privacy Notice for California Residents supplements the information contained in this Privacy Policy, and applies solely to all visitors, users, and others who are California Consumers. We have adopted this notice to comply with the CCPA, and any terms defined in the CCPA have the same meaning when used in this Notice.

Information We Collect

Please refer to section “Collecting and Using Your Personal Data” of this Privacy Policy.

In particular, we have collected the following categories of Personal Data within the last twelve (12) months:

 

Category
Example
Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

Yes

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

 

Some personal information included in this category may overlap with other categories.

(limited to name, address and  phone numbers)

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

NO

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

NO

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

NO

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

YES

G. Geolocation data.

Physical location or movements.

YES

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

NO

I. Professional or employment-related information.

Current or past job history or performance evaluations.

YES

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

NO

K. Inferences drawn from other personal information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

NO

 

Sharing Personal Data

We may disclose your Personal Data to a third party for a business purpose, as described in section “Disclosure of Your Personal Data” and “Transfer of your Personal Data”. When we disclose Personal Data for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Data confidential and not use it for any purpose except performing the contract. Please, be advised that the CCPA prohibits third parties who purchase the Personal Data we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

In the preceding twelve (12) months, Company has disclosed the following categories of Personal Data for a business purpose with service providers it uses:

  • Category A: Identifiers.
  • Category B: California Customer Records personal information categories (limited to name, address and phone numbers).
  • Category F: Internet or other similar network activity.
  • Category G: Geolocation data; and
  • Category I: Professional or employment-related information.

Your Rights under the CCPA

The CCPA provides Consumers, who are California residents with specific rights regarding their Personal Data. This section describes your CCPA rights and explains how to exercise those rights.

a) Access to Specific Information and Data Portability Rights

You have the right to request that We disclose certain information to you about its collection and use of your Personal Data over the past twelve (12) months. Once We receive and confirm your verifiable consumer request, We will disclose to you:

  • The categories of Personal Information We have collected about you;
  • The categories of sources for Personal Information We have collected about you;
  • Our business or commercial purpose for collecting that Personal Data;
  • The categories of third parties with whom We have shared that Personal Data;
  • The specific pieces of Personal Information it has collected about you (also called a “data portability request”);
  • If We have sold or disclosed your Personal Data for a business purpose, two separate lists disclosing:
    • Sales, identifying the Personal Data categories that each category of recipient purchased; and 
    • Disclosures for a business purpose, identifying the Personal Data categories that each category of recipient obtained. 
b) Deletion Request Rights 

You have the right to request that We delete any of your Personal Data that We have collected from you and retained, subject to certain exceptions. Once We receive and confirm your verifiable consumer request, We will delete (and direct our service providers to delete) your Personal Data from its records, unless an exception applies. 

We may deny your deletion request if retaining the information is necessary for Us, or Our service provider(s) to: 

  • Complete the transaction for which We collected the Personal Data, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
  • Debug products to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent;
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with Us; 
  • Comply with a legal obligation;
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
c) Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to Us at: privacy@redroverk12.com, or mail Us at 559 W. Uwchlan Ave, Suite 200, Exton, PA 19341. 

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Data. You may also make a verifiable consumer request on behalf of your minor child. 

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows Us to reasonably verify you are the person about whom We have collected Personal Data or an authorized representative;
  • Describe your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Data if it cannot verify your identity or authority to make the request and confirm the Personal Data relates to you. 

Making a verifiable consumer request does not require you to create an account with Us. 

We will only use Personal Data provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. 

Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if you are a California Consumer, You can email us at privacy@redroverk12.com, or mail us at  559 W. Uwchlan Ave, Suite 200, Exton, PA 19341.

The Company will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.

Selling Personal Data 

We do not sell Personal Data. 

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, We will not:

  • Deny you goods or services;

  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
  • Provide you a different level or quality of goods or services; or
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Website

You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:

  • From Our "Cookie Consent" notice banner

The opt out will place a cookie on Your Device that is unique to the browser You use to opt out. If you change browsers or delete the cookies saved by your browser, you will need to opt out again.

Mobile Devices

Your mobile Device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:

  • "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices
  • "Limit Ad Tracking" on iOS devices

You can also stop the collection of location information from Your mobile Device by changing the preferences on your mobile device.

 

“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

Your California Privacy Rights (California's Shine the Light law)

Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with Us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.

If you'd like to request more information under the California Shine the Light law, and if you are a California resident, You can contact Us using the contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code section 22581 allow California residents under the age of 16 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if you are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.

Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. 

The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our website and this privacy policy to check for any changes.

Changes to this Privacy Policy are effective when they are posted on this page.

Privacy Questions

If you have any questions about this Privacy Policy, You can contact us by email at: privacy@redroverk12.com, or by mail at:

 

Red Rover K-12

559 W. Uwchlan Ave, Suite 200

Exton, PA 19341.