Viitai LLC Privacy Notice
This Privacy Notice is effective as of October 18th, 2020.
At Viitai LLC ("Viitai"), we recognize the importance of protecting your personal information and are committed to processing it responsibly and in compliance with applicable data protection laws in all countries in which we operate.
SCOPE OF THIS PRIVACY NOTICE:
In the normal course of its business activities, Viitai collects, uses, and sometimes shares personal information of various individuals and organizations in order to run its day-to-day operations and provide products and services for your use. This Privacy Notice applies to all users of Viitai products and services and to visitors to Viitai websites and Viitai operated social media sites (we refer to the Viitai website, social media sites, and our products and services as "Sites and/or Services" in this Notice). This Notice describes Viitai's general privacy practices that apply to such personal information collection and use.
This Notice does not apply to: (1) personal information relating to employees, applicants for employment, or contractors providing services to Viitai , (2) user generated or created content that is uploaded to Viitai products and services, or (3) circumstances when Viitai is acting as a processor of personal data on behalf of a data controller.
1. TYPES OF PERSONAL INFORMATION WE COLLECT
In describing our collection, use, and sharing of information in this Notice, we refer to our collection and use of "Personal Information." "Personal Information," as used in this Notice, is any information that identifies, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. Examples of Personal Information include identifying information such as an individual's name, username, email address, phone number, or other similar identifiers, information about products or services purchased or used, browsing and search history, and location data.
2. HOW WE COLLECT YOUR PERSONAL INFORMATION
We collect Personal Information in four ways:
We may collect, use, and share (with Viitai partners, service providers and licensees) precise location data, including the real-time location of your mobile or fixed location device.
We use analytics tools and other third-party technologies to collect information in the form of various usage and user metrics when you interact with, use, or install Viitai Sites and/or Services. These tools and technologies collect and analyze certain types of information, including cookies, IP addresses, device and software identifiers, referring and exit URLs, onsite behavior and usage information, feature use metrics and statistics, usage and purchase history, MAC Address, mobile unique device ID, and other similar information (referred to as "Collected Data").
The third parties that provide these analytics tools may also use the Collected Data with other information they have independently gathered from other websites and/or other online or mobile products and services you have used or interacted with, pursuant to their own policies or privacy notices. In addition to our use of technologies as described herein, we may permit certain third party companies to help us tailor advertising we think may be of interest to you based on your use of our Sites and/or Services and to otherwise collect and use data about your use of our Sites and/or Services. For more information about this practice, please see the "Third-Party Advertising Technologies" section below.
We may use a variety of methods, including "cookies" to collect information.
What is a cookie?
Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. The contents of these cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow a website to recognize a user's device and save information between website pages or on-line sessions. You can find more information about cookies at: All About Cookies.Org.
Cookies do lots of different jobs, such as letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience. They can also help to ensure advertisements you see online are more relevant to you and your interests.
The cookies used on our Sites and/or Services by category are described below.
We may permit certain third-party companies to help us tailor advertising we think may be of interest to users and to collect and use other data about user activities on our Sites and/or Services (e.g., to allow them to tailor ads on third party services). We do not sell your information to third parties. These companies may deliver ads that might place cookies and otherwise track user behavior. These companies may use information about user behavior in order to provide customized advertisements across various services and products.
In the course of providing these services, products, or placing advertisements, these third-party companies may place or recognize a unique cookie on your computer and may record information to these cookies based upon your activities on any of our Sites and/or Services and on third party websites. Each of these companies uses this cookie information according to their own privacy and security policies. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out as indicated in this Notice. Please note this does not opt you out of being delivered advertising; you will continue to receive generic ads.
Opting Out of Cookies
By using the Sites and/or Services, you consent to the placement of the cookies referenced above. You can, however, set your browser to notify you when you receive a cookie, giving you the chance to decide whether or not to accept it. You may also change your cookie settings through preference options in our Sites and/or Services, where applicable. We will indicate that upon selecting your preferences, we will use a cookie to remember your preferences.
Personal Information relating to Children
We do not knowingly seek or collect Personal Information from users under the age of 16 (a "Child" or "Children"), except to the extent that Viitai may collect limited Personal Information from Children (but not their email addresses) where that Child's school or school district has contracted with Viitai to collect the Personal Information from the Children for the educational context authorized by the school or school district.
In the event we learn we have collected Personal Information from a Child without parental or guardian consent being obtained by his or her school or school district, or if we learn a Child has provided us Personal Information beyond what we request when he or she signs up for any of our Sites and/or Services, we will delete that Personal Information as quickly as possible. If you believe a Child may have provided us Personal Information beyond what is requested when signing up for any of our Sites and/or Services, or a student's school or school district has not obtained parental or guardian consent for a Child, please contact us at privacy@Viitai.com.
If you are a user under the age of 16 and your parent or guardian signed up for an account for you with Viitai using a password or access ID provided by your school, your parent or guardian may be able to view all information contained in your account. This includes information such as messages between you and your teacher, and grades you received on your assignment.
3. HOW WE USE YOUR PERSONAL INFORMATION
We only use your data as expressly set forth in this Notice. If a need arises to use your data for a secondary purpose, we will provide you prior notice of such use.
Communication and Responding to Requests
We use your information, including Personal Information, to provide you with different services such as customer support, processing transactions, responding to users' requests, sending newsletters, updates, special offers and advertisements, seeking your opinions and feedback, and connecting you to other users of Viitai Sites and/or Services as well as to products and services of our partners and licensees. You can opt-out of newsletters and updates, special offers and advertisements and offering your opinions and feedback.
We use your information, including Personal Information, behavioral metrics, and other non-personally identifiable information to operate, provide, improve, and maintain our Sites and/or Services, to develop new products and services, to personalize other content for you, and for other administrative and internal business purposes. You can opt-out of providing optimization information by following the instructions in the applicable Sites and/or Services.
We use your information, including Personal Information, behavioral metrics, geo-location data, demographic data, and marketing preferences to personalize and display advertisements and other content for you. You can opt-out of providing these marketing preferences. If you elect to opt-out, you may not be able to receive advertising content personalized for you, however you still receive non-personalized marketing content.
We use your information, including Personal Information, and any other information you submit directly or through passive means to provide you with various ways to connect and share content (e.g., web content , user generated videos, text, drawings, and screen and lecture captures, and quizzing features, media, tools, services and other products) with third parties. For example, we may provide you with the opportunity to email a link to certain content to another person. To use this feature, we may require you to provide certain Personal Information including your email address and the email address of each person to whom you send the link.
We also may allow you to share links to content with users of various third-party services (e.g., social networking, search and sharing services). By using any of these third-party services to share links to content, you permit us to access, use and disclose any information relating to your account on each such third party service (such as your user name and profile information) that we make available for your use. We do not store your user credentials to these third party services.
4. REASONS WE SHARE YOUR PERSONAL INFORMATION
We do not share your Personal Information with third parties except as noted herein. We may share your Personal Information as necessary to maintain business operations, such as with vendors working on our behalf (for example, delivery of services and digital advertising); as required by law or to respond to legal process; to maintain the security of our products; to monitor and enforce our rights as a licensor; to respond to an inquiry from a licensee concerning information in connection with users registered under their corporate email domain, to protect Viitai's customers, employees, rights, or property; as part of a merger or acquisition; or with your expressed consent. If we share your Personal Information with a third party acting on our behalf, we remain liable for any harm that is caused by that third party if they have processed Personal Information in a manner inconsistent with this Privacy Notice or applicable law.
5. WHERE WE STORE AND PROCESS YOUR PERSONAL INFORMATION
Personal Information collected by Viitai may be stored and processed in your region, in the United States, and in any other country where Viitai, its processors, or its sub-processors operate and/or have facilities. The storage location(s) are chosen in order to operate efficiently, to improve performance, and to create redundancies in order to protect the data in the event of an outage or other problem. We take steps to ensure that the data we collect under this Notice is processed according to the provisions of this Notice and the requirements of applicable law relating to the Personal Information or you as a data subject. We may transfer Personal Information from the European Union or European Economic Area ("EU"), or the United Kingdom, to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection.
Finally, as a last resort and in limited situations, EU and Swiss individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism. See the Privacy Shield Arbitration Panel for more details
The U.S. Federal Trade Commission has jurisdiction over Viitai's compliance with the Privacy Shield Principles. You can visit: Privacy Shield for more information.
6. HOW WE SECURE YOUR PERSONAL INFORMATION
Viitai uses a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. While we implement safeguards designed to protect your Personal Information, no security system is impenetrable and, due to the inherent nature of the internet, we cannot guarantee that data, during transmission through the internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others. You should take steps to protect the security of your user account information, login, and password.
7. HOW LONG WE RETAIN YOUR PERSONAL INFORMATION
We retain Personal Information for as long as necessary to provide the products and fulfill the transactions you have requested, or for other legitimate purposes such as complying with our legal obligations, resolving disputes, enforcing our agreements, and improving our products. Because these needs can vary for different data types, the context of our interactions with you or your use of products, actual data retention periods can vary significantly.
When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize the Personal Information or, if this is not possible (for example, because your Personal Information has been stored in backup archives), we then securely store your Personal Information and isolate it from any further processing until deletion is possible.
When we collect Personal Information as a processor on behalf of the controller, the controller is the party who provides instructions on deleting or anonymizing the Personal Information.
8. HOW TO ACCESS AND CONTROL YOUR PERSONAL INFORMATION
You may access and review the Personal Information Viitai stores about you and correct any factual errors. Most of your Personal Information may be accessed and corrected by simply logging into your account and accessing your profile. For any other changes, please contact firstname.lastname@example.org.
RESIDENTS OF THE EU
Legal basis for processing personal information (EEA and UK visitors only)
If you are a visitor from the European Economic Area or the UK, our legal basis for collecting and using the Personal Information described above depends on the Personal Information concerned and the specific context in which we collect it.
However, we normally collect Personal Information from you only where we have your consent to do so, where we need the Personal Information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms as described in Section 3. In some cases, we may also have a legal obligation to collect Personal Information from you or may otherwise need the Personal Information to protect your vital interests or those of another person.
If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided under the "How to contact us" heading below.
If you are an EU resident, you have the following data protection rights:
When Viitai is the controller of your Personal Information, you can exercise your rights by contacting us using the information provided in the "How to contact us" section heading below.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with the requirements of applicable data protection laws.
If you are a California resident as defined by the California Consumer Privacy Act (the "CCPA"), you have the following data protection rights:
9. NOTICE REGARDING AUTOMATED DECISION-MAKING AND PROFILING
In some instances, our use of your Personal Information may result in automated decisions being taken (including profiling).
Automated decisions mean a decision concerning you is made automatically on the basis of a computer determination (using software algorithms), without our human review. For example, we use automated decisions to provide targeted advertising on our Services that may be of interest to you. You can opt-out of targeted advertising by contacting us using the information provided in the "How to contact us" section heading below.
To exercise your data subject rights, navigate to CONTACT to start the request process.
If you have a privacy-related
concern complaint, or question, please contact us at:
Or, you may Call us using the following information:
Residents of the EU also have the right to file a complaint with the data protection authority listed below or another supervisory authority ("DPA").
Dr. Stefan Brink
Phone number: 0049 711 6155 41-0
12. CHANGES TO NOTICE
Please note that this Privacy Notice may change from time to time. If there are material changes to this Privacy Notice or in how we use your personal information, we will post a notice on our home page that this Privacy Notice has changed. You are also encouraged to periodically review this Privacy Notice to stay informed on how we are protecting your personal information.