Privacy Notice

Effective Date: November 2020

Introduction

As a provider of digital learning systems for educators and students, 3GStrong LLC (“3GStrong”) is committed to protecting the privacy of our end users. We do collect Personally Identifiable Information that we use to provide, maintain and improve the Sites.

We are providing the below information so that you can understand how we protect and use your information. If you are under 18, we suggest that you review this information with your parents. This information applies to all end users of our digital learning system.

If 3GStrong is a service provider to your institution, your institution is best able to provide you with a full understanding of their privacy practices and more information on how their end user’s Personally Identifiable Information (PI) is collected, shared, and used. To obtain more detailed information about how PI is collected, used, and shared by your educational institution, please contact the appropriate individual at that institution.

In limited circumstances, end users may also be customers of 3GStrong and 3GStrong may market to them as a customer. For example, end users may purchase products or create personal accounts in our web sites. In these circumstances, they would be treated as a customer. This Privacy Notice also applies to end users with respect to the information collected and processed as part of a course of instruction within the digital learning solution as determined by their educational institution or employer. Aggregated de-identified end user PI is leveraged by 3GStrong to improve existing or develop new educational products and services.

We follow privacy laws and regulations that are applicable to our company and our services in the areas where we do business. Should our privacy practices change, we will update it here, but more importantly, we will notify your educational institution in writing and obtain their consent before implementing any material impact to your privacy rights.

Contact us: Any questions or complaints regarding this notice or the collection, use, disclosure, or transfer of PI collected by your educational institution through our digital learning systems should be directed to the appropriate representative at your educational institution. Otherwise, if you have purchased or received a 3GStrong product outside of an educational institution, please direct any questions or complaints to the 3GStrong by emailing [email protected].

What is Personally Identifiable Information (PI)?

Personally Identifiable Information, or PI, shall mean any information relating to an identified or identifiable natural person ("data subject") including personal data as defined under applicable local law. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

What PI do we collect?

We collect PI, such as contact information, education details, or payment information, in order to provide you with the product and/or service requested. We, or our service providers on our behalf, collect PI and other information when you access and/or submit PI on one of our web sites or interact with us at an event. You are not required to provide PI; however, in order to use certain services, we may need to collect certain PI for that service to function properly (e.g., to finalize your purchase) or for us to provide you with requested information.

Depending on the service or transaction, the PI we collect includes information from the following categories:

Name, initials or contact information - On our consumer web sites, we collect your name, initials or contact information when you create an account or purchase a product on our online We also collect your email address. We also collect this information if you connect with us via your social media account as an existing or potential customer.
Payment card industry data such as credit card number, billing address, - If you make an online purchase from us, in addition to your name, we collect payment information through a third-party website, which includes billing and shipping addresses and credit card data to process your transaction.
Communications - If you choose to communicate with or receive communications from 3GStrong via phone, text, chat, email, or any other Sites for technical support, customer service, or other assistance, those interactions may be recorded and monitored to deliver the service or information requested by

We automatically collect computer metadata and content to provide, improve, and maintain our products and services.

When you visit or make transactions on our web sites, we automatically collect certain information from you through the use of cookies, web beacons or other tracking mechanisms. This includes information about your experience such as your IP address, operating systems, pages viewed, and time spent. This allows 3GStrong to collect information about customer usage and online behavior to tailor marketing to areas that may be more appropriate for the customer.

Third parties also collect information automatically from you across websites and over time through the use of their own cookies, web beacons, and tracking mechanisms. This information is used to enable the functions of the site, as well as customize, maintain, and improve our web sites. You may disable cookies via your browser or third-party mechanisms. However, some features of our services may not function properly without them.

You can change your Web browser's Internet preferences to disable or delete cookies, although that may affect certain functions on this site. To learn how to manage your cookies, please follow the instructions for your specific browser.

If you wish to opt out of the use of data collected on our site to send you targeted advertising during your visits to other websites, you should adjust your browser preferences to not accept cookies.

How do we use PI and on what legal basis?

We will use PI to provide the requested service or to process transactions such as information requests or purchases in order to meet our contractual obligations to you.

We will also process your PI to meet our legitimate interests, for example to personalize your experience and to deliver relevant content to you; to maintain and improve our services; to generate and analyze statistics about your use of the services; and to detect, prevent, or respond to fraud, intellectual property infringement, violations of law, violations of our rights or Terms of Use, or other misuse of the Sites.

Except as described in this notice, we limit the use, collection, and disclosure of your PI to deliver the service or information requested by you. We do not collect, use, or disclose PI that is not reasonably related to the purposes described within this notice without prior notification. Your information may be combined in an aggregate and de-identified manner in order to maintain and/or improve our services.

Do we sell or use your PI to market to you?

We will not sell end user PI or use information from educational records for marketing purposes. We will not sell PI to other organizations, nor will we market to students using the information from their educational records (education records are defined as records directly related to a student and maintained by an educational agency or institution, or by a party acting for the agency or institution).

When do we share your PI with third parties?

In general, we only share your PI in order to provide, maintain, or improve our products or services, or respond to legal requests.

Other Web Sites and Features – We may share your PI with third-party business partners for the purpose of providing the service to you. These third-party business partners include cloud service providers, learning management systems (LMS), other educational software providers, etc. These business partners will be given limited access to the PI that is reasonably necessary to deliver the service, and we will require that such third parties follow the same privacy and security practices as 3GStrong.
Business Transfer – In the event of a sale, merger or acquisition, we will be able to transfer your PI to a separate entity. We will require this entity to use your PI only for authorized purposes and by authorized persons in a manner consistent with the choices end users have made under this notice, and that security, integrity, and privacy of your PI is maintained.
Agents/Service providers – We hire other companies to perform certain business-related functions on our behalf and according to our instructions. For example, we provide your PI to service providers that host our Sites data in the cloud.
Educational Institutions – As we provide products and services to your school, we share your data with approved individuals at your school, such as administrators or educators.
Law Enforcement – In the event that 3GStrong receives a legal demand for end user data from a law enforcement agency, that request will only be honored if:
The request complies with all laws and clearly establishes the legal need for disclosure.
The request is related to a specific investigation and specific user accounts are implicated in that investigation.
Whenever legally permissible, users shall receive notice that their information is being requested.

3GStrong reserves the right to disclose to third parties non-personally identifiable information about our users and their use of the 3GStrong services. For example, 3GStrong may disclose aggregate data about the overall patterns or demographics of the users of the 3GStrong products or services.

What privacy controls and choices do we offer you?

You have the rights to access, export, be informed about, rectify, object to the further processing of, restrict the processing of, and withdraw consent to the processing of, and erase your PI.

Access and rectification: We strive to ensure that information we have about you is accurate and You may obtain confirmation as to whether or not PI concerning you exists, regardless of whether PI has already been recorded, and to be communicated such information in a readily understandable form. If you want to review the PI you have provided to us or believe that the information we have about you is inaccurate, you should make a request by following the instructions below.
Choice & Objection to processing: With limited exceptions, you may choose to change how we use your PI at any time by following the instructions below on making a However, if the PI is required in order to provide you with the service or process a transaction, you may not be able to opt-out without canceling the transaction or service. You may object, in whole or in part, on legitimate grounds, to the processing of your PI, even where such processing is relevant to the purpose of the collection. In addition, you may choose whether to share information about yourself and the use of our sites with third parties such as social media sites. You can also choose whether to receive marketing messages from us (see your options in our “Do we use your PI to market to you?” section above) and you may object, in whole or in part, to such processing.
Restriction of processing: In specific cases (e.g., if you challenge the accuracy of the PI, while this is being checked), you can request a restriction on the processing of your PI, which can only be processed to file or defend
Information: You may be informed a) of the source of the PI; b) of the purposes and methods of the processing; c) of the logic applied to the processing, if processing is carried out with the help of electronic means; d) of the identity of the data controller and data processors; and e) of the entities or categories of entities to whom the PI may be communicated and who may have access to such PI in their capacity as data processor(s) or person(s) in charge of the
Data portability: You may request that we export your PI from our systems in a readily accessible file If completed, this means you will have received a copy of your PI that we have retained as a result of you doing business with 3g Strong.
Withdraw consent: Where we are using your PI with your consent, you may withdraw your consent at any time, though this will not affect the lawfulness of our uses of your PI prior to the
Erasure: You may request erasure, anonymization or blocking of PI that have been processed unlawfully, including PI whose retention is unnecessary for the purposes for which it has been collected or subsequently processed, and will obtain certification to the effect that such operations, as well as their contents, have been notified to the entities to whom the data were communicated, unless this requirement proves impossible or involves a manifestly disproportionate At your request, in such instances, we may therefore delete or deidentify your information. However, you should be aware that doing this may limit your use of our services. For example, if you request the deletion of your account within an ecommerce portal, you may be required to re-enter this information should you wish to make another purchase.

To exercise any of your data subject rights, you should contact 3GStrong.

How do we protect your PI?

Our IT security team has established industry standard security measures to protect your PI from unauthorized access and use. 3GStrong takes reasonable precautions to protect your information. When you submit personal information via the website, your information is protected both online and off-line. 3GStrong utilizes reasonable security measures to protect the security and confidentiality of your PI from unauthorized access and use.

How long do we retain your data?

We will retain your data for the minimum amount of time necessary to accomplish the purpose for which it was collected, and thereafter no longer than is permitted under 3GStrong’s data retention policies. We will retain and use your data as necessary to comply with our obligations, resolve disputes and enforce agreements.

What rights do you have?

As a user, you have the rights to access, export, be informed about, rectify, object to the further processing of, restrict the processing of, withdraw consent to the processing of, and erase your PI. If you are a student at an educational institution using a 3GStrong product, you should direct any requests to exercise your data subject rights to the appropriate representative at your institution. If you are an educator or administrator, you may reach out to 3GStrong directly on the requests below:

Access and rectification – We strive to ensure that the PI we have about you is accurate and current. You may obtain confirmation as to whether or not PI concerning you exists, regardless of whether PI has already been recorded, and be communicated such information in a readily understandable form.
Choice & Objection to processing – With limited exceptions, you may choose to change how we use your PI at any time. However, if the PI is required in order to provide you with the service or process a transaction, you may not be able to opt-out without canceling the transaction or service. You may object, in whole or in part, on legitimate grounds, to the processing of your PI, even where such processing is relevant to the purpose of the collection. Please know that if we do receive a request to objection to the further processing of your information, you may no longer be able to access or use the digital learning solution.
Withdraw consent – Your educational institution is responsible for obtaining your consent, where required. 3GStrong obtains consent from your institution to collect, process, and store your PI.
Restriction of processing: In specific cases (e.g., if you challenge the accuracy of the PI, while this is being checked), you can request a restriction on the processing of your PI, which can only be processed to file or defend claims.
Information – You have the right to be informed a) of the source of the PI; b) of the purposes and methods of the processing; c) of the logic applied to the processing, if processing is carried out with the help of electronic means; d) of the identity of the data controller and data processors; and e) of the entities or categories of entities to whom the PI may be communicated and who may have access to such PI in their capacity as data processor(s) or person(s) in charge of the processing.
Data portability – You have the right to export your PI from our systems in a readily accessible file type.
Erasure – You may request erasure, anonymization or blocking of a) PI that have been processed unlawfully; b) PI whose retention is unnecessary for the purposes for which it has been collected or subsequently processed. You can obtain certification to the effect that such operations, as well as their contents, have been notified to the entities to whom the data were communicated, unless this requirement proves impossible or involves a manifestly disproportionate effort. Since your educational institution has hired us to manage this information for them, we ask that you or your parent make any request to delete your information directly to your school. Please know that if we do receive a request to delete your information, you may no longer be able to access or use the digital learning solution.

How do we protect your PI?

Our IT security team has established industry standard security measures to protect your PI from unauthorized access and use. 3GStrong takes reasonable precautions to protect your information. When you submit PI via the digital learning system, your information is protected both online and off-line. 3GStrong utilizes reasonable security measures to protect the security and confidentiality of your PI from unauthorized access and use.

How long do we retain your data?

A Note to Parents:

Protecting privacy and maintaining the trust of our customers, students, and their parents is and always will be a key priority for us. To enhance learning, we need access to data, measurement, insight and other feedback that inform us about students' knowledge, skill levels and learning development.

Our goal is to use the data obtained in the course of current learning activities to provide learning; not to drive commerce.

Questions?

Effective Date November 2020

Our commitment to privacy and innovation is a key part of our culture:

We have implemented policies and procedures to support customers in their compliance with privacy laws, including: COPPA and FERPA.
We conduct regular scans of our applications to prevent and detect security breaches. We recognize that no system is 100% secure, but we take steps to prevent and mitigate the impact of adverse events.

Educational institutions, as data controllers, are ultimately responsible for providing a full understanding of the privacy practices around how their students' Personally Identifiable Information (PI) is collected, shared, and used. To obtain more detailed information about how data is collected, used, and shared by an educational institution, please contact the appropriate representative at that institution.

For further details on our privacy practices around student data, please review the Privacy Notice. The Privacy Notice details practices around how we collect and use student information, whether they are a student at an educational institution or an individual using a product on their own.

If you have purchased a 3GStrong product for your child, please also review the Customer Data Privacy Notice for information on how we handle your personally identifiable information.

If you have purchased an 3GStrong product and created an account for yourself as an educator, please also review the Privacy Notice. The Privacy Notice also applies to educators at educational institutions.

If you choose to communicate with or receive communications from 3GStrong via phone, text, chat, email, or any other Sites for technical support, customer service, or other assistance, those interactions may be recorded and monitored to deliver the information requested by you.