ATOM LEARNING PRIVACY POLICY

Last updated September 28, 2021

INTRODUCTION

ATOM LEARNING LTD (“we” or “us” or “our”) respects the privacy of our users (“user” or “you”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website www.atomlearning.com, including any other media form, media channel, mobile website, or mobile application related or connected thereto (collectively, the “Site”). Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access the site.

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Last Updated” date of this Privacy Policy. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Site, and you waive the right to receive specific notice of each such change or modification.

You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Site after the date such revised Privacy Policy is posted.

If you are under the age of 13 years, please do not access our website or the Service without permission from your parent, legal guardian, or another consenting adult, such as your teacher or tutor.

COLLECTION OF YOUR INFORMATION

We may collect information about you in a variety of ways. The information we may collect on the Site includes:

Personal Data Personally identifiable information, such as your name, email address, telephone number, and demographic information, such as your age and gender that you voluntarily give to us when you register with the Site, or when you choose to participate in various activities related to the Site. You are under no obligation to provide us with personal information of any kind, however your refusal to do so may prevent you from using certain features of the Site.

Derivative Data Information our servers automatically collect when you access the Site, such as your IP address, your browser type, your operating system, your access times, and the pages you have viewed directly before and after accessing the Site.

Financial Data Financial information, such as data related to your payment method (e.g. valid credit card number, card brand, expiration date) that we may collect when you purchase, order, return, exchange, or request information about our services from the Site. We do not store any financial data on the Site. All financial information is stored by our payment processor, Stripe, and you are encouraged to review their privacy policy and contact them directly for responses to your questions.

Mobile Device Data Device information, such as your mobile device model and manufacturer, if you access the Site from a mobile device.

Third-Party Data Information from third parties, such as personal information or network friends, if you connect your account to the third party and grant the Site permission to access this information.

USE OF YOUR INFORMATION

Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you via the Site to:

  • Assist law enforcement and respond to subpoena.

  • Compile anonymous statistical data and analysis for use internally or with third parties.

  • Create and manage your account.

  • Deliver targeted advertising, coupons, newsletters, and other information regarding promotions and the Site to you.

  • Email you regarding your account or order.

  • Fulfill and manage purchases, orders, payments, and other transactions related to the Site.

  • Increase the efficiency and operation of the Site.

  • Monitor and analyze usage and trends to improve your experience with the Site.

  • Notify you of updates to the Site.

  • Offer new products, services, and/or recommendations to you.

  • Perform other business activities as needed.

  • Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.

  • Process payments and refunds.

  • Request feedback and contact you about your use of the Site.

  • Resolve disputes and troubleshoot problems.

  • Respond to product and customer service requests.

  • Send you a newsletter.

  • Solicit support for the Site.

DISCLOSURE OF YOUR INFORMATION

We may share information we have collected about you in certain situations. Your information may be disclosed as follows:

By Law or to Protect Rights If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.

Third-Party Service Providers We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.

Marketing Communications With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law.

Affiliates We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

Business Partners We may share your information with our business partners to offer you certain products, services or promotions.

Other Third Parties We may share your information with advertisers and investors for the purpose of conducting general business analysis. We may also share your information with such third parties for marketing purposes, as permitted by law.

Sale or Bankruptcy If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur and that the transferee may decline honor commitments we made in this Privacy Policy.

We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly.

TRACKING TECHNOLOGIES

Cookies and Web Beacons We may use cookies, web beacons, tracking pixels, and other tracking technologies on the Site to help customize the Site and improve your experience. When you access the Site, your personal information is not collected through the use of tracking technology. Most browsers are set to accept cookies by default. You can remove or reject cookies, but be aware that such action could affect the availability and functionality of the Site. You may not decline web beacons. However, they can be rendered ineffective by declining all cookies or by modifying your web browser’s settings to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis.

Website Analytics

We may also partner with selected third-party vendors, such as Cloudfare, Google Analytics, Mixpanel and others, to allow tracking technologies and remarketing services on the Site through the use of first party cookies and third-party cookies, to, among other things, analyze and track users’ use of the Site, determine the popularity of certain content, and better understand online activity. By accessing the Site, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policy and contact them directly for responses to your questions. We do not transfer personal information to these third-party vendors. However, if you do not want any information to be collected and used by tracking technologies, you can visit the third-party vendor or the Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool.

You should be aware that getting a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.

THIRD-PARTY WEBSITES

The Site may contain links to third-party websites and applications of interest, including advertisements and external services, that are not affiliated with us. Once you have used these links to leave the Site, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from the Site.

SECURITY OF YOUR INFORMATION

We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal Information.

POLICY FOR CHILDREN

Our Site is an education resource for children under the age of 13 and therefore we will collect children’s personal information as described in this Privacy Policy.

Even if our digital learning courses are offered in conjunction with an outside partner, the partner will not receive any individual personal information from users of the Site, including children. We may provide partners with aggregate or de-identified information about users.

What Information Do We Collect About Children and Why?

As described in further detail below, we collect some personal information from children so that we can track their progress through our courses. Data is retained for education purposes only.

How Information is Collected? We may collect information about children directly from children, as well as automatically through a child’s use of our Site and Services. We will not require a child to disclose more information than is reasonably necessary to use our Services.

Information We Collect Directly We collect the child’s first name, last name, pronoun, and date of birth. We require this information to correctly address the child while using the Site and to produce Scaled Scores based on their age. Parents or legal guardians provide this information on behalf of their child and must confirm they consent to us processing the data during the use of the Site. The Site does not collect personal information directly from children.

Parents may ask us to stop collecting personal information from their child by emailing us at [email protected]; however, in such cases the child will not be able to take or complete our courses. If a parent directs us to stop collecting and using a child’s personal information, we must disable his or her use of our courses to ensure that no information is collected.

Information We Collect Automatically. We may automatically collect the following information about a child’s use of our Site through cookies and other technologies: domain name; browser type and operating system; web pages viewed; links clicked; the length of time spent on our Site; the length of time our courses were taken; Google Analytics statistics; the referring URL, or the webpage that led the child to our Site; language information; device name and model; operating system type, name, and version; and activities within our Site. We may also collect IP address, device identifier, or a similar unique identifier from users of our Site, including children; we only use such identifiers to support the internal operations of our Site and we do not use such identifiers to collect information about the child outside of our Site.

Other Information We Collect About Children. We collect information about children’s performance and activities on our Site, including completion of courses. This information is for internal use only and will not be disclosed to other entities; however, we do not use this information in personally identifiable form for our own commercial purposes. Before we analyze or use any activity data for our own commercial purposes, we de-identify and/or aggregate such information.

How We Use Children’s Information We use personal information collected from children for the following purposes:

  • To provide our Services; and

  • To respond to customer service and technical support issues and requests.

We de-identify and/or aggregate the information we collect from children under 13 before we use it for any other purposes, as noted below.

Unique Identifiers We only collect and use unique identifiers, such as IP addresses, as necessary to operate our Site, including to maintain or analyze their functioning; perform network communications; authenticate users or personalize content; and protect the security or integrity of users and our Site. We never use unique identifiers to track users across third-party apps or websites.

Aggregate or De-identified Information We may use aggregate or de-identified information about children for research, analysis, and similar purposes. When we do so, we strip out names, e-mail, contact information, and other personal identifiers. We may use aggregate or de-identified information for the following purposes:

  • To better understand how users access and use our Site and Services;

  • To improve our Site and Services and respond to user desires and preferences; and

  • To conduct research or analysis, including research and analysis by third parties.

How We Share Children’s Information We do not sell children’s personal information, and a child may not make his or her personal information public through our services. In general, we may disclose the personal information that we collect about children to provide our Services, to comply with the law, and to protect us and other users of our Site. For example, we may share children’s personal information as follows:

  • Service Providers. We may disclose the information we collect from children to third-party vendors, service providers, contractors, or agents who perform functions on our behalf.

  • Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the personal information we have collected from our users to the other company.

  • In Response to Legal Process. We also may disclose the personal information we collect in order to comply with the law, a judicial proceeding, court order, subpoena, or other legal process.

  • To Protect Us and Others. We also may disclose the personal information we collect where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service, Privacy Policy, or this COPPA Policy, or as evidence in litigation in which we are involved.

  • With Parents. Parents may request information about the information we have collected from their child by contacting us at [email protected]

We may also use and share aggregate or de-identified information about users with third parties for marketing, research, or similar purposes.

Your Rights to Review, Delete, and Control Our Use of Children’s Personal Information Parents have a right to review the information we have collected about their children and students, respectively, and to delete it, and to tell us to stop using it. To exercise these rights, you may contact us at [email protected] You will be required to authenticate yourself as the child’s parent to receive information about that child. Please note that copies of information may remain in cached or archived form on our systems after you request us to delete it.

CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems [and our mobile applications] include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy./Most web browsers and some mobile operating systems [and our mobile applications] include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. If you set the DNT signal on your browser, we will respond to such DNT browser signals.

OPTIONS REGARDING YOUR INFORMATION

Account Information You may at any time review or change the information in your account or terminate your account by:

  • Logging into your account settings and updating your account

  • Contacting us using the contact information provided below Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use, and/or comply with legal requirements.

Emails and Communications If you no longer wish to receive correspondence, emails, or other communications from us, you may opt-out by:

  • Noting your preferences at the time you register your account with the Site

  • Logging into your account settings and updating your preferences

  • Contacting us using the contact information provided below If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.

CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Site, you have the right to request removal of unwanted data that you publicly post on the Site. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Site, but please be aware that the data may not be completely or comprehensively removed from our systems.

CONTACT US

If you have questions or comments about this Privacy Policy, please contact us at:

Atom Learning Tagwright House 35-41 Westland Place London N1 7LP UK [email protected]

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Atom Learning Ltd. is registered and incorporated in England and Wales. Company Registration Number: 10867907 VAT number: 316903508 Copyright Atom Learning Ltd. All rights reserved.