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PRIVACY POLICY

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.

Zinc (individually and collectively, “Zinc,” “We,” “Our” or “Us”) is committed to protecting Your privacy and this Privacy Policy sets out our privacy practices. Please take the time to review this Privacy Policy carefully as it tells You how Your personal information will be treated by us as “data controller” under applicable data protection laws.

By using the Zinc Reader website at games.zinclearninglabs.com (the “Website”), the Zinc Vocab (the “Application”) and our services (“Services”), You unconditionally agree to be bound by this Privacy Policy. Zinc wants to offer You the best possible Internet experience. Consequently, additional functions, features, products or services are incorporated into the Website and the Application from time to time. For convenience, the words “user,” “You” and “Your” as used in this Privacy Policy refer to users of the Website and/or the Application.

For the purposes of this Privacy Policy, “Personal Information” is information that (i) You or Your Teacher provide to Zinc and (ii) personally identifies You. Personal Information includes Your name, email address and other data that can be used to personally identify or contact You or otherwise be associated with You.

This, and our commitment to protecting the privacy of Your Personal Information, may result in periodic changes to this Privacy Policy. Any questions regarding our Privacy Policy should be directed to Zinc' Privacy Policy Manager at support@zinclearninglabs.com (see the section “Contacting us” below).

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 karthik@zinclearninglabs.com.

THE INFORMATION WE OBTAIN AND MANAGE

The Personal Information that the Zinc may collect from You and/or manage includes, but is not limited to:

  • Your name;
  • Your contact information such as email addresses, IP addresses, telephone numbers and any other information that We collect that could personally identify You; and
  • If you are a student who joins a school or classroom on the Website that is created by the school You attend, the individual and cumulative scores that You achieve in games and activities that You access and use on the Website (“Your Game Scores”).

Except as otherwise provided in this Privacy Policy, Zinc will store all information provided by You in its secure data servers to the extent necessary to provide the Services to You and/or Your Teacher during the time You are in the Teacher’s class.

HOW WE OBTAIN THE PERSONAL INFORMATION

Zinc may obtain, collect, retain, store or otherwise maintain Your Personal Information from the following sources:

  • Information that You provide to Us when You register to use and use the Website and/or the Application;
  • Information that You provide to Us when you engage in games and activities on the Website and/or the Application;
  • Information that results from You engaging in games and activities on the Website and/or the Application;
  • Information that You provide to Us when You contact Zinc;
  • Your responses to communications from Zinc. From time to time, Zinc may communicate with You through email, postal mail or other forms of electronic communications regarding the Website and/or the Application, Your use of the Website, the Application and the games and activities which you played or engaged in on the Website and/or the Application; and
  • If you are a student, from teachers, tutors, schools and other educational providers and entities to whom You, your parent or your guardian has provided Your Personal Information and Your parent or guardian has not objected to those third parties accessing and using such Personal Information.

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.

WHY DO WE COLLECT AND USE PERSONAL INFORMATION?

In order to:

  1. Maintain a record of your completion of games and activities on the Website and/or the Application;
  2. Maintain a record of the scores You achieve in the games You play on Website and/or the Application;
  3. Respond to communications that You initiate with Us;
  4. Contact You in order to resolve problems or other issues that You may experience in connection with Your access or use of the Website, the Application or with any goods or services supplied to You;
  5. Send You information about the Website, the Application the games and activities available on the Website and the Application and Your use of the Website and/or the Application and the games and activities available on the Website (if You have chosen to receive such information); and
  6. If you are a student, enable your teacher, tutor or other educational provider to observe Your progress with and completion of the Website’s games and activities.

We need to collect and process personal information about You. We will ask You for this information through our Website or when You register to use the Website and/or the Application. Certain information is collected automatically, as described later in this Privacy Policy.

If you are based in the EU, the lawful basis for which we process your information is:

  • Your consent;
  • processing is necessary for the performance of a contract to which you are a party. If you fail to provide this information we may be unable to perform the contract;
  • processing is necessary for compliance with our legal obligations.
  • processing is necessary for the purpose of the legitimate interest pursued by us except where your rights as a data subject override our legitimate interest.

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.

DISCLOSING YOUR INFORMATION TO OTHERS

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.

If Zinc desires to use Your Personal Information for any purpose other than those described in this Privacy Policy, Zinc will request Your or, if You are a student, Your parent’s or guardian’s consent prior to such use. If You, or if You are a student, Your parent or guardian does not consent or You otherwise decline to submit Your Personal Information in response to such a request, Zinc may not be able to provide to You some or all of the features available on the Website.

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.

THIRD PARTY INFORMATION

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:

  • only contact You by text, email or recorded call if it has proof of your opt-in consent within the last six months which specifically named Zinc;
  • market products or services which are the same or similar to those that You originally consented to receiving marketing for;
  • screen the names on the bought-in list against its own list of people who have said they do not want to hear from Zinc;
  • inform You that we obtained Your details from a bought-in list;
  • provide You with an appropriate privacy notice;
  • delete any data that is irrelevant or excessive;
  • ensure that the seller of the bought-in list has the right to share Your information with Zinc; and
  • ensure there are appropriate safeguards in place for transferring Your information to the US.

EMAIL SOLICITATIONS

Zinc only sends email solicitation to users who have agreed, through this Privacy Policy, on a third party Website or by other means, to receive emails from Zinc.

International Transfers (EU based users)

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.

HOW LONG WE KEEP THE PERSONAL INFORMATION FOR

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.

HOW WE KEEP THE PERSONAL INFORMATION SECURE

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.

LOG FILES/IP ADDRESSES

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.

NON-PERSONAL INFORMATION

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.

INFORMATION PLACED ON YOUR COMPUTER

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.

We use cookies to:

  • Remember that You have logged-on to the Website before so that You do not have to log-on to the Website each time that You use it;
  • Remember that You have visited us before so that We can identify the number of unique visitors we receive. This allows Us to make sure We have enough capacity for the number of users that We get; and
  • Collect anonymous statistical information about how You use the Website (including how long You spend on the Website) and from where You have come to the Website so that We can improve the Website and learn which parts of the Website are most popular with visitors;

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.

IMPROVING OUR SERVICE

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.

KEEPING OUR RECORDS ACCURATE

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.

"CONTACT US" INFORMATION

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.

LINKS

This Privacy Policy only pertains to the Website. Other Website and portals, such as those to which the Website links to or may, in the future, link to the Website, including, without limitation, Facebook and Twitter may have their own privacy policies. We encourage You as well as Your parent or guardian to read the privacy policies and terms of use of the Website and portals that You visit through links placed on the Website as well as those for Website that provide links to the Website. You and Your parent or guardian should contact these Websites directly if You, your parent or guardian have any questions about their use of Your Personal Information. Zinc is not responsible for any use of Your Personal Information or any other type of Your information when You use such third party sites and services.

INFORMATION SHARING AND ONWARD TRANSFER

Zinc reserves the right to sell or otherwise share some or all of Your Personal Information with other companies or individuals outside of Zinc if Zinc becomes involved in a merger, acquisition, or any form of sale of all of its assets. In such circumstances, Zinc will (i) require that the entity receiving Your Personal Information agree to adhere to the privacy principles of the K-12 School Service Provider Pledge to Safeguard Student Privacy, which can be found at https://studentprivacypledge.org/privacy-pledge/; and (ii) provide notice before Personal Information is transferred and becomes subject to a different privacy policy.

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.

CHANGES TO THIS PRIVACY POLICY

Zinc may, at its sole discretion, revise this Privacy Policy at any time in a manner consistent with applicable laws and regulations. When We revise this policy, including changes to Zinc’ use of Your Personal Information, we will incorporate the revisions into this policy and will revise the "last revised" date at the bottom of this web page. We will notify You by email when any changes to this Privacy Policy are made, and You, or if You are a student, Your parent or guardian will be required to accept the revised Privacy Policy by clicking on the appropriate button before You may use the Application or Services again. We recommend that You and Your parent or guardian review those changes in order to remain informed about how Zinc uses Your Personal Information.

CALIFORNIA USER CONSUMER RIGHTS

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 dca@dca.ca.gov . For more information about protecting Your privacy, You may wish to visit: www.ftc.gov.

CHILDREN'S/MINOR'S USE OF THE SITE

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 contest its accuracy and we need to verify whether it is accurate
  • the processing is unlawful and you ask us to restrict use of it instead of erasing it
  • we no longer need the information for the purpose of processing, but you need it to establish or defend legal claims
  • you have objected to processing of your information being necessary for the performance of a task carried out in the public interest, or for the purposes of our legitimate interests. The restriction would apply while we carry out a balancing act between your rights and our legitimate interests.
  • you exercise your right to restrict processing, we would still need to process your information for the purpose of exercising or defending legal claims, protecting the rights of another person or for public interest reasons.

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.

USE OF THE WEBSITE AND APPLICATION

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.

SEVERABILITY

If any provision of this Privacy Policy is found to be illegal, void, or unenforceable, that provision will be deemed severed from the balance of the agreement and will not affect the validity and enforceability of the remaining provisions, which will continue in full force and effect.

ACKNOWLEDGEMENT

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:

  • You have read, understand and agree to Zinc’s Privacy Policy;
  • If you are under 18 years of age, Your parent or guardian have read, understand and agree to Zinc’s Privacy Policy;
  • You have the right to provide the information that You submit to Zinc, and the information You submit is accurate, complete and truthful;
  • If you are under 18 years of age, Your parent or guardian consents to the provision of such information and the information; and
  • If You do not agree to the terms of this Privacy Policy, then do not provide Your information to Zinc through any means. In such case, Zinc is relieved of any of its obligations to You as set forth in this Privacy Policy; and
  • If you are under 18 years of age and Your parent or guardian does not agree to the terms of this Privacy Policy, then do not provide Your information to Zinc through any means. In such case, Zinc is relieved of any of its obligations to You as set forth in this Privacy Policy.

If You have any questions regarding this Privacy Policy, please contact Zinc’s Privacy Policy Manager at support@zinclearninglabs.com.

Revised September 2018