Effective as of March 1, 2019
- our use of your personal information is necessary for complying with our legal obligations; or
- where neither of the above apply, use of your personal information is necessary for our legitimate interests or the legitimate interests of others. Our legitimate interests are to:
- run, grow and develop our business;
- operate our Site and provide our services;
- select appropriately skilled and qualified suppliers;
- build relationships with partners and academic institutions;
- carry out research and statistical analysis;
- carry out marketing and business development; and
- for internal administrative and auditing purposes.
If we rely on our (or another person’s) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person’s) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information.
We may process your personal information in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time after giving it, as described below).
If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by writing to us at email@example.com or delete your account and we will stop doing so. However, if you withdraw your consent, this may impact the ability for us to be able to provide our services to you.
For the purposes of the EU General Data Protection Regulation ((EU) 2016/679), we, uLearnMoney, are the “data controller”. If you have any questions about this policy or about how we use your Personal Information, please contact us at firstname.lastname@example.org.
WHAT INFORMATION DO WE COLLECT ABOUT YOU AND WHY?
We may collect information about you or from you, including about your organization, when you affirmatively provide it, from third parties, and automatically through your use of our Site or Services.
Information You Affirmatively Provide
If you wish to use some of our Services, you will need to provide us with some of your Personal Information. For example, to register for an educational course with uLearnMoney, you may be required to provide your full name, email address, phone number, social media account information, identification card number, a password, and some information about your education as well as employment status and organization. You may also provide additional information to us, such as information about you (your demographics, your interests, your goals) or your organization (its size, location, funding, and capacity) and response given in the surveys, quizzes, comment sections, forums, assignments in the online courses, and communication within the uLearnMoney community..
Information We Collect Automatically
We may automatically collect Personal Information and other information and data about you and your use of our Site or Services through technologies, including but not limited to cookies and web beacons. These technologies may collect information which includes but is not limited to your domain name; your browser type and operating system; web pages you view; links you click; your IP address; the length of time you visit our Site and/or use our Services; and the referring URL, or the webpage that led you to our Site.
Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).
Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We may use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site.
Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We may use persistent cookies to track aggregate and statistical information about user activity, and potentially to place information about our services on our Site and on third-party sites.
Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies will be able to browse certain areas of the Site, but some features may not function.
HOW DO WE USE YOUR INFORMATION?
We use the Personal Information and other information we collect from and about you for the following purposes:
- To provide our Services to you, to communicate with you about your use of our Services, to respond to your inquiries, and for other customer service purposes.
- To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Site or our Services.
- For marketing and promotional purposes. For example, we may use your information, such as your email address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you. We also may use the information that we learn about you to assist us in advertising our Services on third party websites.
EU-based users – we will only send you marketing emails where you have opted-in to receive them and you can unsubscribe from these marketing emails at any time.
To better understand and report publicly and to third parties on how users access, use, and benefit from our Site and Services, both on an aggregated and individualized basis, in order to improve our Site and Services and respond to user desires and preferences, and for other research and analytical purposes. We may use automated devices and applications, such as Google Analytics, to help us evaluate usage of our Site and Services. We use these tools to help us improve our Services, performance and user experiences, and understand whether our Services are delivering results for our users and their organizations.
WITH WHOM DO WE SHARE YOUR INFORMATION AND WHY?
We may share your information, including Personal Information and information about your organization, as follows:
- Business Partners and Affiliates. We may disclose the information we collect from you to our business partners who contract with us to help further our mission, and with any affiliates or subsidiaries we may have or create, but only if they agree in writing to protect the privacy and security of the information.
- Service Providers. We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf. We ensure that we have appropriate data privacy safeguards in place with these third party service providers.
- Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or if we under a bankruptcy proceeding involving a transfer of assets, we may transfer the information we have collected from you to the other company.
- In Response to Legal Process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal processes, such as in response to a court order or a subpoena.
- Aggregate and De-Identified Information. We may share aggregated information that is not identifiable to any individual, and otherwise de-identified information, third parties for marketing, advertising, research, or any other lawful purposes. We do not share Personal Information with third parties for their own marketing purposes.
Our Site and Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites.
We have implemented commercially reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee 100% security.
You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
ACCESS TO YOUR PERSONAL INFORMATION
You may modify personal information that you have submitted by logging into your account and updating your profile information; if you are the Administrator for your organization, you may modify organizational information that you have submitted by logging into your account and updating your organization’s dashboard. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site for a period of time and that we will retain records of information previously provided.
If you are an EU citizen and reside in the EU, or are non-EU national residing in the EU, you may have the following rights with respect to the Personal Information you provide to us, to the extent permitted by applicable data protection laws:
- To withdraw any consent that you have provided to us to process your Personal Information.
- To access or rectify your Personal Information.
- To have your Personal Information erased if it is no longer necessary for the purposes for which it was processed, you have withdrawn your consent to, or object to, its processing and there are no other legitimate grounds for processing it or you consider it has been unlawfully processed.
- To have the processing of your Personal Information restricted if you contest its accuracy, its processing is unlawful, we no longer need it but you need it for a legal claim, or you have objected to its processing and await verification of our legitimate grounds for processing it.
- To have your Personal Information transferred to another company under certain circumstances.
- To complain to your national data protection regulator if you feel that your Personal Information has been unlawfully processed.
WHAT CHOICES DO I HAVE REGARDING USE OF MY PERSONAL INFORMATION?
We may send periodic promotional or informational emails to you. For EU-based users: we will only send these to you where you have opted-in to receive them.
If you decide you no longer want to receive these emails from us, you may opt-out at any time by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any Services you have requested or received from us.
INTERNATIONAL TRANSFERS OF INFORMATION
We are an organisation based outside of the United States and so if you provide your Personal Information to us, that Personal Information will not be transferred to the United States for processing and storage. Please note that the laws of our country may not provide as much protection for Personal Information as the laws of the United States.
For EU-based users:
- where you have registered for our Services, we will transfer your Personal Information from the European Economic Area (“EEA”) to the United States for processing in order to provide the Services to you;
- where we need to transfer your Personal Information to a third party business provider which is based outside the EEA, we will ensure a similar degree of protection is afforded to the transferred Personal Information by incorporating specific protective clauses approved by the European Commission into our agreements with the recipient of the data.
CALIFORNIA PRIVACY RIGHTS
Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g. requests made in 2020 will receive information regarding 2019 sharing activities).
To obtain this information, please send an email message to email@example.com with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.
If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at firstname.lastname@example.org.
CHANGES TO THIS POLICY
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically at https://ulearnmoney.com/privacy to familiarize yourself with any amendments to the Policy. If we make any material changes to the Policy, we will post a notice that such changes have been made on the homepage of the Site.