This website is owned and operated by Zinc Learning Labs, Inc. (“Zinc”). We are a company incorporated in the State of New York and our registration number is 4781845.
This policy is prepared in compliance with the requirements of the General Data Protection Regulation (EU) 2016/679 (“GDPR”), as in force from time to time. Where a particular provision applies to EU-based users only, we have made this clear. Our EU representative for data protection matters is Patrick Weber, Attorney, Tacitus Str. 1 e50968 Köln, Germany. Our nominated person for data protection is Karthik Chandrasekharaiah and his contact details are email@example.com.
The Personal Information that the Zinc may collect from You and/or manage includes, but is not limited to:
Zinc may obtain, collect, retain, store or otherwise maintain Your Personal Information from the following sources:
You can decline to provide Your Personal Information to Zinc by not engaging in the activities described above. If You decline to submit Personal Information, Zinc may not be able to or may choose not to provide to You some or all of the features available on the Website and/or the Application or some of the products or services that it offers.
In order to:
If you are based in the EU, the lawful basis for which we process your information is:
Although We do not make it compulsory to give us every item of information We ask for, the more information You volunteer (and the more accurate it is), the better We can tailor our services for You.
Zinc restricts access to Personal Information to those employees, contractors and agents of Zinc and other persons described above whom need to access Personal Information for the purposes specified above. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination, if they fail to meet these obligations.
If You are a student, Zinc may provide Your Personal Information to Your Teacher. Other than the provision of students’ Personal Information to their respective Teachers, Zinc does not provide Personal Information to third parties.
Zinc does not to collect, use, or share Your Personal information for any purposes beyond those set for this in agreement nor does it use Your Personal Information or interaction with the Website for the purposes of advertising or behavioral marketing.
Except as otherwise set forth herein, Zinc does not share Your Personal Information with third parties without Your or, if You are a student, Your parent’s or guardian’s consent, except when We believe that it is reasonably necessary to do so in order to comply with a subpoena or other judicial order or process, as otherwise required by law or in order to enforce Zinc’ Terms of Service. In such circumstances, Your Personal Information may also be disclosed to Zinc attorneys.
If You are a student who joins a school or classroom on the Website that is created by the school You attend, Zinc may provide Your teacher and other personnel from Your school with access to Your name and Your Game Scores.
Except in instances where Zinc provides Your Information to third parties in order to comply with a subpoena or other judicial order or process, as otherwise required by law or in order to enforce Zinc’s Terms of Service, Zinc will only share Your Information with Your teacher and other personnel from Your school.
Zinc may collect or purchase information from third parties (including Teachers) regarding persons who provided information to those third parties. Information provided to Us by the third party may include, but not limited to, individual names, email and postal addresses, telephone numbers, birth dates, genders, and any other information provided to the third party. Zinc uses its reasonable best efforts to ensure that (i) the third party possesses the right to transfer the information to Zinc and (ii) Zinc has received the right to communicate with the persons who provided the information.For EU-based users
In the event that Zinc collects or purchases Your information from a purchased email marketing list, Zinc will:
If you are based in the EU, we will need to transfer your personal information to the USA for the purposes listed in this policy. Rest assured that we will always ensure any transfer is subject to appropriate security measures to safeguard your personal information.
Unless necessary to enforce the Zinc’s Terms of Service or if required by law or court order, we do not retain Your Information for longer than is necessary to provide the Services to You. We will delete Your Information within forty-five (45) days after (a) You terminate Your account with Zinc, (b) Your teacher or educational institution notifies Us that You are no longer using the Services or (c) Your teacher or educational institution notifies Us that Your teacher or educational institution are no longer using the Services. In addition, at the end of each school year, we delete the personal information of all students who used the Services during the school year.
Zinc uses commercially reasonable efforts to ensure that such information is secure and to protect against its loss, misuses, and alteration of the information under Zinc’ direct control. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. Notwithstanding the foregoing, Zinc cannot guarantee that its security measures will prevent its computers from illegal or otherwise unauthorized access.
When You visit the Website, We may automatically log Your IP address (the unique address which identifies Your computer on the internet) which is automatically recognized by Our web server. We use IP addresses to help us administer the Website and to collect broad demographic information for aggregate use.
We may automatically collect non-personally identifiable information about You including, but not limited, the specific types of Services You use, type of Internet browser You use, the location website from which You linked to our Website, browser language, the date and time of Your request, date and time of access, session length and referrer Uniform Resource Locator. You cannot be identified from this information. This information may be shared with third parties for the purpose of analysis and only used to assist Us in providing an effective service on the Website. We may from time to time supply the owners or operators of third party sites from which it is possible to link to our Website with information relating to the number of users linking to our Website from their sites. You cannot be identified from this information.
When You interact with the Website, We try to make that experience simple and meaningful. When You visit the Website, Our web server sends a cookie to Your computer. Cookies are small pieces of information which are issued to Your computer when You visit a Website and which store and sometimes track information about Your use of the Website. A number of cookies We use last only for the duration of Your web session and expire when You close Your browser. Other cookies are used to remember You when You return to the Website and will last for longer.
For example, cookies ensure that You do not need to re-enter Your details every time You visit our Website.
You can erase or block cookies from Your computer if You want to (Your help screen or manual should tell You how to do this), but certain services on the Website may not work correctly if You set Your browser not to accept cookies.
Some of the cookies used by the Website are set by Us, and some are set by third parties who are delivering services on Our behalf.
Most web browsers automatically accept cookies but, if You prefer, You can change Your browser to prevent that or to notify You each time a cookie is set. You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browser. Please note, however, that by blocking or deleting cookies used on the Website, You may not be able to take full advantage of the Website.
In addition to cookies, tracking Gifs may be set by us or third parties in respect of Your use of the Website. Tracking Gifs are small image files within the content of the Website so We or third parties can understand which parts of the Website are visited and whether particular content is of interest.
If You have agreed that We can, staff from Zinc or from our agents, may contact You from time to time by email in order to get Your views and comments on the service we provide to You.
We aim to keep our information about You as accurate as possible. If You would like to review or change the details You have supplied Us with, You may do so at any time using the Contact Us page on the Website. If You have another query relating to Your information, please contact us as set out below.
If You communicate with Us using the means described in the "Contact Us" section of the Website, We may ask You for Personal Information such as Your name or email address. If You are contacting Us with respect to a customer service issue, we may use the Personal Information that You provide to contact You in order to resolve that customer service issue. If necessary to resolve Your customer service issue, the Personal Information that You provide to Us may be shared with third parties in order to resolve the issue. Please understand that by providing such information in connection with a customer service issue, You are giving Your express consent for Us to use Your Personal Information to contact and communicate with You and, if necessary, third parties, regarding that customer service issue.
In addition, Zinc reserves the right to share non-personally identifiable information relating to users of the Website or the Zinc services with our partners. The information will not be linked to any personal identifiable information.
In accordance with California Civil Code Sec. 1789.3, California resident users are entitled to know that they may file grievances and complaints with the California Department of Consumer Affairs, 400 R Street, STE 1080, Sacramento, CA 95814; or by telephone at (916) 445-1254 or (800) 952-5210; or by email to firstname.lastname@example.org . For more information about protecting Your privacy, You may wish to visit: www.ftc.gov.
Consistent with the Federal Children's Online Privacy Protection Act of 1998 (COPPA), we will never knowingly request personally identifiable information from anyone under the age of 13 without requesting parental consent.
With respect to the EU, where online services are provided to a child under the age of 16 and consent is relied on as the basis for the lawful processing of his or her data, we obtain consent from that child’s parent or guardian.Your Rights Under Data Protection Law (If You Are Based in the EU)
If you have created an account with us, you can sign into your account to access and update your information. You can manage your marketing preferences at any time by logging in to Your account and changing Your settings regarding email notifications for in-app use.
You have a right to ask us to confirm whether we are processing information about you, and to request access to this information (‘right of access’). You also have the right to be informed of the safeguards we have in place relating to any transfers of your information to another country.
You may ask us, or we may ask you, to correct information you or we believe is inaccurate, and you may also ask us to remove information which is inaccurate or complete information which is incomplete (‘right to rectification’). If you inform us that your personal data is inaccurate, we will inform relevant third parties with whom we have shared your data so they may update their own records.
We want to ensure that your personal information is accurate and up to date. If any of the information that you have provided us with changes, for example if you change your email address, name, payment details, or if you wish to cancel your registration, please let us know by contacting us.
You have a right to obtain your personal data from us and reuse it for your own purposes, perhaps for another service, without hindering the usability of the data (‘right of portability’).
You have a right to seek the erasure of your data (often referred to as the ‘right to be forgotten’). You may wish to exercise this right for any reason, for example where it is no longer necessary for us to continue holding or processing your personal data you may withdraw your consent. This right is not absolute, as we may need to continue processing this information, for example, to comply with our legal obligations.
You have a right to ask us to restrict our processing of your information (‘right to restriction’) if:
You have a right to prevent us from processing your data for the purposes of marketing.
If you would like to exercise any of your rights above, please let us know using the contact details at the end of this policy. We will act in accordance with your instructions as soon as reasonably possible and there will be no charge.
You have a right to report any of your concerns about our use of your data to the relevant data protection authority in your EU country.
You acknowledge that the personal information You provide to Zinc is collected and stored in the United States and therefore consent to the transfer of information to and storage of the information in the United States, regardless of Your country of domicile.
By completing forms provided by Zinc, providing Your Personal Information through the Website and/or to Zinc, through any means, and by using the Website and services contained therein, You hereby represent and warrant that:
Revised September 2018