Privacy Policy

BEFORE SUBMITTING ANY PERSONAL INFORMATION TO MYKLOVR’ PLEASE REVIEW THE FOLLOWING PRIVACY POLICY.

1. Who’s who?

“myKlovr” refers to Student Global, LLC, a Delaware limited liability company. When “We” or “Us” or “Our” are used in this policy, it is a reference to myKlovr. The “myKlovr Platform” refers to this website and all applications and content provided by myKlovr. The myKlovr Platform and its content are designed to comply with U.S. laws and regulations. “You” or “Your” refers to the person using an account created on the myKlovr Platform, or otherwise using the website accessible through www.myKlovr.com or any other component of the myKlovr Platform. If you are using the myKlovr Platform as part of your job, or on behalf of your employer, “You” or “Your” refers to both you and your employer.

2. What does this Privacy Policy Address?

This myKlovr Privacy Policy (the “Privacy Policy”), applies to the information that We or Our designees collect via the myKlovr Platform or by other means when You use the myKlovr Platform. This Privacy Policy is a part of the myKlovr Terms and Conditions available at http://www.myKlovr.com/terms-conditions (the “Terms”). You accept this Privacy Policy and the Terms by either creating an account on the myKlovr Platform, or otherwise using or accessing the parts of the myKlovr Platform that are accessible without creating an account. If You are using the myKlovr Platform as part of Your job, or on behalf of Your employer, You are accepting it both on behalf of Yourself personally, and on behalf of Your employer.

This Privacy Policy applies to information We ask You to provide to the myKlovr Platform. Any unsolicited information provided by You (e.g. by sending an email to Us or posting a question in an online chat session before You create an account) is non-confidential and will not be treated as private information. When You provide unsolicited information to Us, You grant myKlovr a nonexclusive, royalty-free, worldwide, perpetual, irrevocable, transferable, and fully sub-licensable right to use the unsolicited information for any lawful purpose and without limitation or attribution.

In an effort to alert You further concerning myKlovr’s privacy practices, We may also collect, use or provide Your Personal Information as disclosed in short “Privacy Notices” posted on the myKlovr Platform from time to time, or otherwise provided to You in connection with Your use of the myKlovr Platform. Such Privacy Notices are in addition to, and not in lieu of this Privacy Policy. To the extent they are different from this Privacy Policy, they will apply only to the specific Personal Information expressly discussed in the Privacy Notice. This Privacy Policy is intended to be construed together with any such Privacy Notice.

3. What Information We Gather

3.1 Personal Information

“Personal Information” means individually identifiable information about an individual collected from that individual by myKlovr via the myKlovr Platform or by other means (for example, by You voluntarily submitting Personal Information to Us via the completion of a registration form or in an email You send to Us). The types of Personal Information that We may request include, without limitation, Your name, age, academic performance history, the educational institution in which You are enrolled, Your employer, job title, department, mailing address, email address, and telephone number. Where there are links between the myKlovr Platform and third party sites or social networks, We may collect account information for accounts You use on those third party sites or social networks. In some instances, We may also collect the geo-location data of Your mobile or other device, including, without limitation, GPS-based, Wi-Fi-based, or cell-based location information. Even though We don’t view them as “Personal Information,” We may also collect Your internet protocol (IP) address, MAC address, or other machine or network identifiers as You access the myKlovr Platform. Payment card and financial institution information is collected through our third-party vendors or service providers. We do not store credit card or financial institution information.

We require registration in order for You to use certain features of the myKlovr Platform. As part of the registration process You will be required to provide Us with Personal Information. Some of the Personal Information that We ask You to provide is mandatory and some is voluntary. If You do not provide the mandatory information, You may not be able to use the myKlovr Platform or Your use may be limited to only certain portions. We reserve the right to change which parts of the Website require registration, and which do not, as We modify and update the myKlovr Platform.

3.2 Accessing and Updating Your Personal Information

You may update Your Personal Information via the myKlovr Platform. If You should become aware that Your Personal Information with myKlovr is not complete and accurate, You must promptly update Your Personal Information via Your account. It is Your obligation to ensure that Your Personal Information is kept up to date. We may backup or replicate Personal Information stored through the myKlovr Platform for disaster recovery or other purposes. Updates to your Personal Information will not necessarily be reflected in such backups or replicated data when You make those updates. In the event that any Personal Information is shared with third parties (as permitted in this Privacy Policy), updates will not be reflected in the data stored by those third parties unless or until they request an update from myKlovr and myKlovr provides that update (once again, where permitted by this Privacy Policy).

3.3 Online Tracking

We, and certain service providers operating on Our behalf, collect information about Your activity on the myKlovr Platform and applications using tracking technologies such as cookies. Such technologies are widely used in order to make websites work, or work more efficiently, and to help Us better understand how people use the myKlovr Platform. In addition, We may utilize third party advertising arrangements that involve the use of cookies or web bugs or similar technologies to help ensure that any advertising delivered to You by us or third parties is relevant to Your interests. myKlovr and its designees may use these technologies when You interact with the myKlovr Platform. If You disable these technologies in Your browser, the myKlovr Platform may not operate correctly and You may not be able to use certain of its features.

3.4 Adult Audiences Only

The myKlovr Platform is intended to be used only by persons over 13 years of age. We do not knowingly collect Personal Information or other information from or about children. You agree to notify Us immediately in writing via Your myKlovr account, or by mail at 1350 Avenue of the Americas, 2nd Floor, New York, New York, 10019, or by email at support@myklovr.com, if You become aware that We have received information from or about any such individuals.

3.5 Third Party Sites

Some of Our services may be provided through sites that bear the names and trademarks of Our partners or suppliers, and that are not under Our control. In addition, the myKlovr Platform may contain links or other devices that take You to other websites that are also not within Our control, or pull content from such websites for display on the myKlovr Platform. Certain of those other websites may provide products or services to You directly or on Our behalf. We are not responsible for any aspect of other websites, including, without limitation, the privacy practices, products, services, or content of such websites. This Privacy Policy will not apply to such other websites.

Rather, Your activity and the information that You provide at such other websites will be subject to the privacy policies and other terms and conditions posted at such other websites. You are responsible for reviewing those privacy policies and other terms and conditions prior to providing any Personal Information to those sites, regardless of whether or not You access them in connection with Your use of the myKlovr Platform. In particular, payment information for products and services You purchase through the myKlovr Platform are provided by our third party payment processing service providers. All payment information You provide will be subject to the privacy policies and terms of use of those third party providers. If you have any difficulty locating terms or privacy policies for our payment processing providers, please contact support@myKlovr.com and we will help you find them.

4. How We Use the Personal Information We Gather

Personal Information that You provide to Us is processed and stored on the servers located within the United States. We may change the location of the servers from time to time, including to other countries, and without prior notice to You. Your Personal Information, however, will continue to be protected in accordance with this Privacy Policy. In the event of a change of ownership or restructuring of myKlovr (in whole or in part), any or all Personal Information maintained by myKlovr may be transferred to another entity, and such entity may then change this Privacy Policy in accordance with the myKlovr Terms and Conditions.

myKlovr may store and use Your Personal Information and, without further notice to You, may provide Your Personal Information to myKlovr affiliates or to third parties in order for Us, Our affiliates or third parties to:

  • A. support Our intent to provide’ maintain’ and improve usability of the myKlovr Platform;
  • B. collect and distribute payments;
  • C. provide You with technical support;
  • D. provide You with access to restricted areas of the myKlovr Platform;
  • E. comply with legal requirements’ including’ without limitation’ governmental orders’ civil subpoenas’ or discovery requests;
  • F. enforce the Terms and Conditions of this Privacy Policy and the Terms governing use of the myKlovr Platform’ including’ without limitation’ the investigation of potential violations or suspected illegal activities;
  • G. protect the rights’ property’ safety’ or security of myKlovr’ any of Our users or the public’ or to respond to an emergency; or
  • H. accomplish or attempt to accomplish any other lawful purpose.

Some data, including, but not limited to, the types of services used and the numbers of users We receive daily in various parts of the myKlovr Platform, may be used for statistical, marketing, promotional, or any other lawful purposes. This kind of information is collected in aggregate/statistical form, without identifying any user individually, and may be shared with or sold to third parties, subject to applicable laws and regulations. Aggregate data that does not identify specific individuals is not Personal Information.

5. Protection of the Personal Information We Gather

myKlovr has implemented industry-standard measures to protect the security of the Personal Information We collect via the myKlovr Platform. The financial partners We use to collect and process payment information are PCI DSS (Payment Card Industry Data Security Standard) certified. Regardless of what measures are used to protect Personal Information, no one can guarantee, and We do not guarantee, that Your Personal Information is completely secure at all times. If We determine that Your Personal Information was accessed in an improper manner, We will comply with applicable laws as We understand them and will cooperate with internal investigators or law enforcement (including by possibly disclosing Your Personal Information to such investigators or law enforcement agencies).

Your Personal Information may also be accessed by anyone having the credentials You use to access the myKlovr Platform. Please understand that You are also responsible for maintaining the confidentiality of Your Personal Information to protect it against unauthorized access or use including’ without limitation’ by ensuring that any credentials that enable access to the myKlovr Platform use strong passwords and are not shared with any third party. To the maximum extent permitted by applicable law’ myKlovr disclaims any responsibility or liability for any misuse of Your Personal Information that results from illegal’ improper’ negligent’ malicious’ or inappropriate acts or omissions of You or any third party’ or from any conduct’ other than willful conduct of myKlovr.

myKlovr may retain Your Personal Information for as long as You continue to use the myKlovr Platform’ and for as long thereafter as permitted or required by applicable law. If We delete Your Personal Information’ it may still be contained on backup media or other systems until such times as such media is destroyed or overwritten’ or data on such other systems are otherwise deleted.

6. Your Rights

In accordance with the applicable law’ myKlovr will provide You with access to Your Personal Information and’ as appropriate’ the right to intervene in respect of Your Personal Information. You may also be entitled to request the deletion of Your Personal Information’ in which case’ if myKlovr’ in its sole discretion’ deems deletion of such Personal Information as mandatory or appropriate’ myKlovr may do so; provided’ however that such deletion will mean that You may no longer be permitted to engage in certain activities’ and may not have any further access to records of Your use of the myKlovr Platform. Deletion of Personal Information in this way may also result in your forfeiture of any usage credits or promotional credits earned by You prior to the deletion.

For the purpose of exercising Your rights’ You must submit a written request to Us in accordance with the applicable law via Your myKlovr account’ or by mail at 1350 Avenue of the Americas’ 2nd Floor’ New York’ New York’ 10019′ or by email at support@myklovr.com. In addition’ if You believe that myKlovr has not complied with this Privacy Policy with respect to Your Personal Information’ please submit a sufficiently detailed complaint to Us in any of the foregoing manners. We will promptly investigate Your complaint. Thereafter’ We will take all measures We deem necessary to remedy the issues outlined in Your complaint that We’ in Our sole discretion’ view as justified. If myKlovr deletes Personal Information’ de-identified summaries’ backup copies’ and legal records may continue to contain portions of the Personal Information thereafter.

If You are under eighteen (18) years of age’ You or Your parent or legal guardian may request modification or deletion of Your Personal Information. myKlovr will respond to such requests whether made by You and may respond to requests made by a person who represents to Us that he or she is your parent or guardian’ if myKlovr does not have a good faith basis for disbelieving such representations.

7. Your Choices

You can decide if You want to provide Your Personal Information to myKlovr. If You do not understand and agree to this Privacy Policy DO NOT provide Personal Information to Us. Please note’ however’ that if You do not provide certain Personal Information’ You may not be able to use the myKlovr Platform’ or access certain features of the myKlovr Platform.

If You choose (through the myKlovr Platform) to receive communications regarding special offers’ or any other information’ We may add Your Personal Information to Our email database and use (or direct Our designees to use) Your Personal Information for providing such communications to You. You may later choose to unsubscribe from receiving such communications by following the unsubscribe directions in Our communications. If You provide myKlovr with inconsistent privacy preferences (for example’ by indicating on one occasion that We may provide You with marketing offers and on another occasion that We may not)’ myKlovr will endeavor to update Your privacy preferences in myKlovr’s records with Your latest preference in a timely manner’ but We cannot guarantee how quickly such changes will take effect.

8. Questions or Concerns About this Privacy Policy; Changes to this Privacy Policy

If You have any questions about this Privacy Policy’ please send Your inquiry via e-mail to support@myklovr.com’ or by mail to 1350 Avenue of the Americas’ 2nd Floor’ New York’ New York’ 10019.

myKlovr reserves the right to change this Privacy Policy at any time by posting notice of the changes on the Website. For additional details concerning changes to this Privacy Policy’ please see the Terms. You are responsible for reviewing this Privacy Policy after being exposed to such postings. You can also determine if changes have been made’ by noting the version information at the bottom of this Privacy Policy. If You do not agree with any of the changes that have been made’ Your sole remedy is to cease use of the myKlovr Platform and seek deletion of your Personal Information as described above.

To the maximum extent permitted by applicable law’ the limitations of liability’ dispute resolution requirements’ disclaimers’ and governing law provisions of the Terms will apply to and govern any actual or alleged claims relating to this Privacy Policy.

9. FOR CALIFORNIA RESIDENTS ONLY – Your California Privacy Rights

If you are a California resident using the myKlovr Platform’ the following additional terms apply.

9.1 Do Not Track

In some cases’ some third parties that provide services to Us’ such as for analytics’ may be able to collect information about Your online activities when You use the myKlovr Platform. Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature’ it is not always clear whether users intend for these signals to be transmitted’ or whether they even are aware of them. Consequently’ We do not take actions to respond to automated “Do Not Track” signals at the current time. However’ You can change your privacy preferences regarding the use of cookies and similar tracking technologies through Your browser. You may set Your browser to accept all cookies’ block certain cookies’ require Your consent before a cookie is placed in Your browser’ or block all cookies. Blocking all cookies will affect Your online experience and may prevent you from enjoying the full features offered at the myKlovr Platform. Please consult the “Help” section of Your browser for more information.

If You are a California resident’ You may request information about practices related to disclosing Your personal information to certain third parties and/or opt-out of sharing of Your information with unaffiliated third parties for the third parties’ direct marketing purposes’ if applicable. Please send Your request (along with your full name’ e-mail address’ postal address’ and the subject line labeled “Your California Privacy Rights”) by e-mail at support@myklovr.com.

9.2 Notice for Minors

If You are a California resident under the age of 18′ and a registered user of the myKlovr Platform’ California Business and Professions Code Section 22581 permits You to request and obtain removal of content or information You have publicly posted. To make such a request’ please send an email with a detailed description of the specific content or information to support@myklovr.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information You have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

9.3 SOPIPA Compliance

We do not knowingly engage in any of the following activities with respect to the myKlovr Platform:

  • (a) Targeted advertising on the myKlovr Platform or targeting of advertising on any other site’ service’ or application when the targeting of the advertising is based upon any information’ including covered information and persistent unique identifiers’ that the myKlovr Platform has acquired because of Your use of the myKlovr Platform.
  • (b) Use of information’ including persistent unique identifiers’ created or gathered by the myKlovr Platform to amass a profile about a K-12 student except in furtherance of K-12 school purposes.
  • (c) Sale of a student’s information’ including covered information. This does not apply to the purchase’ merger’ or other type of acquisition of the myKlovr Platform by another entity’ provided that the successor entity continues to be subject to the provisions of this section with respect to previously acquired student information.
  • (d) Disclosure of covered information unless the disclosure is made:
    • i. in furtherance of the K-12 purpose of the myKlovr Platform’ provided the recipient of the covered information disclosed pursuant to this subparagraph:
      • 1. shall not further disclose the information unless done to allow or improve operability and functionality within that student’s classroom or school; and
      • 2. is legally required to comply with subsections (a)-(c);
    • ii. to ensure legal and regulatory compliance;
    • iii. to respond to or participate in judicial process;
    • iv. to protect the safety of users or others or security of the site; or
    • v. to a service provider that is contractually (1) prohibited from using any covered information for any purpose other than providing the contracted service to’ or on behalf of’ myKlovr’ (b) prohibited from disclosing any covered information provided by myKlovr with subsequent third parties’ and (c) required to implement and maintain reasonable security procedures and practices.

These restrictions do not apply to the myKlovr Platform’s use of information for maintaining’ developing’ supporting’ improving’ or diagnosing the myKlovr Platform.

We agree to: (1) implement and maintain reasonable security procedures and practices appropriate to the nature of the covered information’ and protect that information from unauthorized access’ destruction’ use’ modification’ or disclosure; and (2) delete a student’s covered information if the school or district requests deletion of data under the control of the school or district.

Notwithstanding the foregoing’ the myKlovr Platform may disclose covered information under the following circumstances:

  • (1) If other provisions of federal or state law require myKlovr to disclose the information.
  • (2) For legitimate research purposes: (A) as required by state or federal law and subject to the restrictions under applicable state and federal law or (B) as allowed by state or federal law and under the direction of a school’ school district’ or state department of education’ if no covered information is used for any purpose in furtherance of advertising or to amass a profile on the student for purposes other than K-12 school purposes.
  • (3) To a state or local educational agency’ including schools and school districts’ for K-12 school purposes’ as permitted by state or federal law.

Nothing in this section prohibits the myKlovr Platform from using de-identified student covered information as follows:

  • (1) Within the myKlovr Platform or other sites’ services’ or applications owned by the myKlovr to improve educational products.
  • (2) To demonstrate the effectiveness of the myKlovr Platform’s products or services’ including in their marketing.

Nothing in this section prohibits myKlovr from sharing aggregated de-identified student covered information for the development and improvement of educational sites’ services’ or applications.

“Covered information” means personally identifiable information or materials’ in any media or format that meets any of the following:

  • (1) Is created or provided by a student’ or the student’s parent or legal guardian’ to an operator in the course of the student’s’ parent’s’ or legal guardian’s use of the operator’s site’ service’ or application for K-12 school purposes.
  • (2) Is created or provided by an employee or agent of the K-12 school’ school district’ local education agency’ or county office of education’ to an operator.
  • (3) Is gathered by an operator through the operation of a site’ service’ or application with actual knowledge that the site’ service’ or application is used primarily for K-12 school purposes and was designed and marketed for K-12 school purposes and is descriptive of a student or otherwise identifies a student’ including’ but not limited to’ information in the student’s educational record or email’ first and last name’ home address’ telephone number’ email address’ or other information that allows physical or online contact’ discipline records’ test results’ special education data’ juvenile dependency records’ grades’ evaluations’ criminal records’ medical records’ health records’ social security number’ biometric information’ disabilities’ socioeconomic information’ food purchases’ political affiliations’ religious information’ text messages’ documents’ student identifiers’ search activity’ photos’ voice recordings’ or geolocation information.

This section does not limit the ability of the myKlovr Platform to use student data’ including covered information’ for adaptive learning or customized student learning purposes.

February 17th, 2017

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