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, Opt-In, and Opt-Out Choices
By accepting our Terms and Conditions your account will Opt-in to marketing e-mails.
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 way:
- 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”, 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 customercare@GlobalScholar.com.
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:
customercare@GlobalScholar.com
By mail:
GlobalScholar
ATTN: Privacy
1100 112th Ave NE
Suite 100 South Bldg
Bellevue, WA 98004
By phone:
1-877-824-4040
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 customercare@GlobalScholar.com 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.