GlobalScholar Privacy Policy
Effective Date: September 16, 2007.
GlobalScholar is committed to protecting your privacy and to handling your personal
information with care and respect.
This Privacy Policy, which is part of and incorporated into the
GlobalScholar Terms and Conditions of Use (“Terms”), describes how we collect,
use, share and protect your personally identifiable information on the Site. By
accepting this Privacy Policy, you expressly consent to our collection, storage,
use and disclosure of your personal information as described below. Building
on this Privacy Policy, we recognize the need to provide additional privacy protections
for children users who are under the age of 13 as required by the Children’s Online
Privacy Protection Act (“COPPA”). To learn more about our protections for
children under 13 years of age, please refer to our Children’s
Privacy Policy.
All capitalized terms that are not defined herein shall have the meanings ascribed
to them in the Terms.
Information Collection
We collect several types of personally identifiable information about our users:
Information You Provide to Us
- Registration. You can browse our Site without telling us who you are
or revealing any personal information about yourself. But in order to purchase
or teach Courses on the Site, you must first register and provide personally identifiable
information (such as name, email address, password, birth date, preferred language,
and time zone). We may also collect other types of information which we may
associate with personally identifiable information. If you apply to become
an Instructor on the Site, you will be required to provide us with your social security
number and/or taxpayer ID number.
- Purchase/Sale Transactions. If you purchase any Courses on the Site,
our online purchase forms will request financial information (such as credit card
number with expiration date and a billing address or bank account information).
We’ll note the type of services or products ordered or purchased, and the
date of the order or purchase.
- Usage History, Interactive Features and Public Forums. We may also
collect additional personal information when you use some features on the Site and
when you correspond with our customer service representatives by phone, mail or
e-mail. If you use the interactive features or public forums (such as e-mail
messaging) on the Site, you should be aware that any personally identifiable information
you submit in the body of your messages can be read, collected, or used by other
users of these forums, and could be used to send you unsolicited messages.
We are not responsible for the personally identifiable information you choose to
submit in these forums. We reserve the right to terminate the Accounts of
any registered users who use the GlobalScholar messaging system in a manner inconsistent
with the Terms.
Information Collected Through Technology
Our Site collects information through a variety of technical methods to create a
“profile” of your preferences and for various purposes related to our business.
We collect information from your interaction with our Site, services, content
and advertising, including computer and connection information, statistics on page
views, traffic to and from the sites, ad data, IP address and standard web log information.
We tie your personally identifiable information and your purchasing history
to information in your profile, in order to provide tailored promotions and marketing
offers and to improve the content of the Site for you.
The following methods may involve the transmission of information either directly
to us or to another party authorized by us to collect information on our behalf:
- Cookies We use “cookies” (small files placed on your hard drive) on certain
pages to help analyze our web page flow; customize our services, content and advertising;
identify you and maintain your signed-in status; measure promotional effectiveness;
and promote trust and safety in the usage of the Site. You are always free
to decline our cookies if your browser permits, although doing so may interfere
with your use of our Site. You may also encounter cookies from third parties
on other websites accessible from our Site; we do not control such websites or their
use of such cookies.
- Web Beacons. We may employ a software technology called clear gifs (a.k.a.
Web Beacons) that help us better manage content on our Site by informing us what
content is effective. We tie the information gathered such technology to our
users’ personally identifiable information.
- Log Files. As is true of most websites, we automatically gather certain information
(such as internet protocol (IP) addresses, browser type, internet service provider
(ISP), referring/exit pages, operating system, date/time stamp, and clickstream
data) and store it in log files. We use this information, which does not identify
individual users, to analyze trends, to administer the Site, to track users’ movements
around the Site and to gather demographic information about our user base as a whole.
We may also link this data to personally identifiable information.
Information That We Collect from Others
We may also occasionally supplement the personal information you submitted to us
and the information we collected through technology with information from third
party sources.
If you would like to offer a Course on our Site and you are not affiliated with
a school district, we require that you go through an application and pre-qualification
process as further described in the Additional Terms
and Conditions for the Instructor. As part of that application process,
we will use a third party service to conduct background checks as permitted by law.
Use of Information
Our primary purpose in collecting personal information is to provide you with a
safe, smooth, efficient, and customized experience. We may use your personal
information to:
- verify your eligibility to be a registered user (i.e. you are over the age of 13);
- verify permission granted to children (i.e., under the age of 13) to use the Site;
- compare information for accuracy and verify it with third parties (such as performing
background checks for users who wish to become Instructors and to offer a Course,
who are not otherwise affiliated with a school district registered on our Site);
- provide the services and customer support you request;
- charge and collect bills, issue credits and debits, and disburse payments in connection
with the transactions;
- store all communications sent through the Site;
- resolve disputes and troubleshoot problems;
- prevent potentially prohibited or illegal activities, and enforce our
Terms;
- customize, measure, and improve our services and the Site’s content and advertising;
and
- tell you about targeted marketing of products, service updates, special deals, and
promotional offers as well as confirm the opening of any HTML-based emails to gauge
the effectiveness of certain communications and effectiveness of marketing campaigns
based on the elections in your Account settings.
We will also communicate with you by email in response to your inquiries, to provide
any assistance you request, to manage your Account (such as billing and refund issues),
and to send you strictly administrative, transaction or operation-related announcements
on rare occasions when it is necessary to do so (such as if our service is temporarily
suspended for maintenance or updates to the policies). Generally, you may not opt
out of these non-promotional communications. But if you do not wish to receive
these administrative, transaction or operation-related communications, you have
the option to deactivate your Account by contacting Customer Support.
Information Sharing and Disclosure
Your Personal Information
Personal information about our users is an important part of our business. We
are not in the business of selling or renting your personal information to
third parties for their marketing purposes without your consent.
We may share your personal information (such as email address) with our corporate
affiliates or corporate partners for their promotional uses unless you elect to
“opt out.” If you do not “opt out” or if you consent to such sharing in the
course of using a specific service or purchasing a particular Course, you authorize
us to disclose your personal information to our corporate affiliates or selected
corporate partners who may send marketing communications about their goods and services.
If you are an Instructor, we will not share your social security number and/or taxpayer
ID number (which you were required to provide as part of the application process
to become an Instructor) with any third parties except as necessary to perform background
checks with third party sources, to disburse funds for Courses you offer, or as
otherwise noted below.
GlobalScholar has the right to share your personal information for the following
purposes which are not subject to your “opt-out” choices:
- Corporate Agents and Third Party Providers. We employ other companies
and individuals to perform functions on our behalf with respect to our business
operations. Examples include fraud investigations, providing customer service,
processing credit card payments, sending postal mail and e-mail, removing repetitive
information from user lists, analyzing data, providing marketing assistance, and
providing search results and links (including paid listings and links). Except
as separately permitted by other provisions in this Privacy Policy, these companies
are allowed to gather, receive, and use your personal information only as needed
to perform their functions or as required by law.
- Authorized Third Parties. In certain circumstances, your dealings with
a third party may have authorized that third party to obtain your personal information
from GlobalScholar and to use that information in accordance with the third party’s
own privacy practices and policies. We will provide your information to such
third parties only to the extent you explicitly authorized us to do so.
- Parents.We operate a “bright lights environment” on our Site. If
you are the Parent of a child under the age of 13 who created the child’s Account,
we will share with you all messages and communications to and from your child that
are sent through and stored in our system.
- Business Transitions. In the event GlobalScholar goes through a business
transition, such as a merger, acquisition by another company, or sale of all or
a portion of its assets, your personally identifiable information will likely be
among the assets transferred as part of such transaction. If we purchase a
business, the personally identifiable information received with that business will
be treated in accordance with this Privacy Policy if it is practicable and permissible
to do so. If we sell a business, we will include provisions in the selling
contract requiring the purchaser to treat your personal information in the same
manner required by the Privacy Policy effective at the time of closing. You
will be notified via a prominent notice on our Site for 30 days of any such change
in ownership or control of your personal information.
- Legal Disclaimer. In an effort to respect your privacy and our ability
to keep the Site free from bad actors, we reserve the right to release your Account
and other personal information when we believe such release is appropriate to: (a)
comply with the law (including to meet our tax reporting obligations), or to respond
to legal requirements (subpoena, court order or substantially similar legal
procedure served on GlobalScholar); (b) enforce or apply our Terms
and other policies; and (c) protect the rights, property, or safety of GlobalScholar,
our users, or others when we believe in good faith that the disclosure of information
is necessary to prevent imminent physical harm or financial loss or to report suspected
illegal activity (including exchanging information with other companies and organizations
for fraud protection). In such events, we will disclose information relevant to
the investigation, such as name, city, state, zip code, telephone number, email
address, User ID history, IP address, fraud complaints, transactional history, and
social security number and/or taxpayer ID number (if applicable). This does
not include selling, renting, sharing, or otherwise disclosing personally identifiable
information from users for commercial purposes.
Aggregate Information (non-personally identifiable)
We reserve the right to share aggregated demographic information about our user
base (without linking to personally identifiable information about individual users)
or de-personalized individual information (removal of name and other personally
identifying characteristics) with our corporate affiliates and corporate partners.
Given the nature of this information, there are no restrictions under this
Privacy Policy upon the right of GlobalScholar to aggregate or de-personalize your
personal information.
Communication Preferences and Opt-Out Choices
You have a choice to give or not to give us your consent to use your personal information
for marketing purposes and to send you marketing e-mail. When you choose to
“opt out,” you decline to give us your consent (a) to disclose your personal
information with our corporate affiliates or corporate partners for their marketing
purposes, and (b) to receive marketing communications or promotional materials via
email from us, any corporate affiliates, or corporate partners.
You can exercise and change your opt-out choices in the following ways:
- during the registration process on the Site; or
- after registration, by accessing your Account settings, or by following the “unsubscribe”
directions provided in the marketing email sent to you.
If you choose to “opt out” after registration, it may take up to ten (10) days after
you “opt out” for your election to be fully effective. Our systems require
time to update and promotional mailings using personal information shared before
you elected to opt out may already be in process. Thus, your personal information
might continue to be shared with our corporate affiliates and corporate partners
and you might continue to receive promotional materials from GlobalScholar, our
corporate affiliates and corporate partners for up to ten (10) business days after
you have changed your opt-out election.
No Spam, Spyware or Spoofing
We and our users do not tolerate spam. Make sure to set your Communication Preferences
for your Account so we communicate to you as you prefer. You are not allowed
to add any other Site user, even a user who has purchased a Course from you, to
your mailing list (email or postal mail) without such user’s express consent. To
report Site-related spam or spoof emails to GlobalScholar, please forward the email
to
.
You may not use our communication tools to send spam or otherwise send content that
would violate our Terms. We reserve the right to
automatically scan and manually filter messages to check for spam, viruses, phishing
attacks and other malicious activity or illegal or prohibited content.
Security
The security and confidentiality of your personal information is extremely important
to us. Your information is stored on our servers located in the United States.
We treat data as an asset that must be protected and use technical (i.e.,
Secure Sockets Layer (SSL) software for encryption, passwords, physical security,
etc.), administrative, and physical security measures to protect your personal information
against unauthorized access and disclosure. We follow generally accepted industry
standards to protect the personal information submitted to us during transmission
and after we receive it.
Please be aware that despite our best efforts, no method of transmission over the
Internet or method of electronic storage is 100% secure and impenetrable. While
we strive to use commercially acceptable means to protect your personal information,
we cannot guarantee, and you should not expect, absolute security. It is important
for you to protect against unauthorized access to your password and to your computer.
Accessing, Reviewing and Changing Your Personal Information
You can see, review and change most of your personal information online through
your account preferences. Generally, we cannot manually modify your personal
information through any other means because it is very difficult to verify your
identity remotely. You must promptly update your personal information if it
changes or is inaccurate.
Deactivating Your GlobalScholar Account
You may deactivate your Account by contacting Customer Support. Upon
your request, we will close your Account and remove your personal information and
posted Course (if applicable) from the Site as soon as reasonably possible, based
on your Account activity and in accordance with applicable law. We do retain
personal information from closed Accounts to comply with law, prevent fraud, collect
any fees owed, resolve disputes, troubleshoot problems, assist with any investigations,
enforce our Terms, and take other actions otherwise permitted
by law.
Links to Other Sites and Third Party Advertisers
Our Site may include third-party advertising and links to other websites that are
not owned or controlled by GlobalScholar.
To the extent these third parties are not our corporate partners, we do not provide
any personally identifiable information to these third-party websites or to advertisers
and Internet advertising companies working on their behalf (also called “ad networks”
or “network advertisers”). These network advertisers sometimes use technology
to send (or “serve”) their advertisements that appear on our Site directly to your
browser. They automatically receive your IP address when this happens. They
may also use cookies, JavaScript, web beacons, and other technologies to measure
the effectiveness of their ads and to personalize advertising content.
When you click on an advertisement on our Site that links to a third party website
or a network advertiser, then you are leaving our Site. This Privacy Policy
will not apply to your personally identifiable information collected on that third
party’s website. We are not responsible for the privacy practices of such
third parties or network advertisers and you must read the privacy policy posted
on their respective websites to see how your personally identifiable information
will be handled.
Changes in this Privacy Policy
Please see our Terms for details on how we will provide
notice of changes in this Privacy Policy.
Your California Privacy Rights
Beginning on January 1, 2005, California Civil Code Section 1798.83 permits our
visitors who are California residents to request certain information regarding our
disclosure of personal information to third parties for their direct marketing purposes.
To make such a request, please send an e-mail or write us using the email
or postal address listed under the Contact Us section.
Contact Us
To contact us with any questions, comments or suggestions regarding our Privacy
Policy or our Children’s Privacy Policy:
By e-mail:
By mail:
GlobalScholar
ATTN: Privacy
1100 112th Avenue NE, Suite 100
Bellevue, WA 98004-8577
By phone:
1-425-646-5700
Children’s Privacy Policy
The Children’s Privacy Policy is designed to describe GlobalScholar’s privacy policies
and principles with respect to children under the age of 13. Children’s Online
Privacy Protection Act (“COPPA”) requires that we inform Parents about how we collect,
use, and disclose personal information from children under 13 years of age and that
we obtain the consent of Parents in order for such children to use certain features
of our Site.
Collection of Personally Identifiable Information About Children
Children can surf on the Site and view content without giving any personal information
to us. But to use the services and participate in certain features available
on the Site, children will need to be a registered user. Children under 13
years of age can only get a registered GlobalScholar account (“Account”) if their
Parent creates one for them and provides verifiable consent.
We also operate a “bright lights” environment; we will store all of the child’s
emails and communications through the Site after his or her Account is activated.
So during the registration, we give the Parent the option to stay involved after
the child is signed up. If the Parent requests access to the child’s e-mails
and activities on the Site, we will send him or her all the recorded communications
and activities of the child on a weekly basis.
Note that all sites that are directed to children under 13 are prohibited by law
from conditioning a child’s participation in an online activity on the child’s providing
more personal information than is reasonably necessary. If a Parent allows
us to collect personal information about his or her child, we may also link certain
Information Collected Through Technology to that personal
information. We do not entice children, by the prospect of a special game,
prize, or other activity, to provide more information than is reasonably necessary
to participate in an activity.
Use of Personally Identifiable Information About Children
We will use the personally identifiable information that we collected about the
child to personalize our communications with the child regarding the Courses on
the Site. For example, if the child’s Account is associated with a particular
school district registered on our Site, we will share that child’s Site activity
information with that school district, which will use it solely for educational
purposes, and we will send personalized communications to the child regarding the
different Courses sponsored or provided by his or her particular school district
on the Site.
We will also use cookies to help to enhance and personalize your child’s experience
with the Site. Cookies will be used to “remember” your child and his or her particular
preferences to customize the child’s experience on the Site. We may use anonymous
information about the use of the Site for research purposes and to improve our Site.
We will not sell any information collected by cookies or use the information
for commerce-related purposes.
Disclosure of Personally Identifiable Information About Children
As a matter of policy, we do not disclose personally identifiable information about
children to third parties.
There are, however, a few exceptions. We may disclose such information about
a child to school districts registered on our Site which are associated with the
child’s Account, as noted above. We may also disclose such information to third
parties to the extent reasonably necessary to: protect the security of integrity
of our sites; to enforce our Terms and take precautions
against liability; to respond to judicial process; or to the extent permitted under
provisions of law, to provide information to law enforcement agencies or for an
investigation related to public safety. Additionally, in the event that all
or substantially all of the assets relating to the Site are transferred or sold
to another entity, personally identifiable information submitted to us may be transferred
to the acquiring entity.
To protect the child’s personal information from disclosure to third parties while
participating in certain interactive features of the Site, we have created some
additional safeguards. The child’s real e-mail address will never be publicly
disclosed or used by us on the Site because each Account will have an alias GlobalScholar
e-mail address that is linked to the child’s real email address so that all communications
from other Site users will go through the Site, get recorded and forwarded to the
child’s actual e-mail. Only the child’s first name and first initial of the
last name will be displayed while the child is logged on the Site. However, note
that we have no control over what content children communicate through their alias
e-mail addresses or certain areas of the Site. Therefore, Parents take full responsibility
for monitoring such communications
Notification and Obtaining Consent for Collection of Personally Identifiable Information
As part of the registration process when a Parent creates an Account for a child,
we will provide notification by displaying this Children’s Privacy Policy (along
with the Terms) in order to obtain his or her express consent
to our collection of personally identifiable information from their children.
Right to Access, Change or Delete Personally Identifiable Information About Children
Each Parent will have the option to view a transcript of all emails, discussions
or content trail of the child’s activities on the Site as part of the “bright lights
environment” that allows the Parent to monitor the child’s activities on the Site.
Parents may review the personally identifiable information provided about their
children, change how we use it, refuse to permit us to collect further personally
identifiable information from their children, and request that the personally identifiable
information we collected be deleted from our records or changed. Parents may
contact our Customer Service department via e-mail at
to do so. Please include the child’s
email address in the e-mail so that we can better assist you with your inquiry or
request.
Notification of Changes to Children’s Privacy Policy
Please see our Terms for details on how we will provide
notice of changes in the Privacy Policy, including the Children’s Privacy Policy.
In addition to what is stated in the Terms, we will provide
parents notice by e-mail of any material changes in the way we intend to collect,
use, and/or share children’s personal information. Please note that, at all
times, parents should update their personal information to provide us current e-mail
addresses. We will apply material changes in our Children’s Privacy Policy
only in conformance with applicable law, including any applicable provisions of
COPPA that require parental consent.