Last Updated: January 5, 2022
EdCast is committed to protecting the privacy of its Users whose information is collected and stored while using EdCast’s Services through our Website. We intend to comply with all applicable consumer privacy laws and regulations with respect to our processing, storing, and use of your Personal Information.
WE DO NOT SELL YOUR PERSONAL INFORMATION. WE DO NOT GIVE ACCESS TO YOUR PERSONAL INFORMATION TO THIRD PARTIES EXCEPT TO SUBPROCESSORS TO ASSIST US IN THE PROVISION OF OUR SERVICES TO YOU.
We provide a state of the art, AI powered, cloud-based, educational, talent experience platform (“TXP”),a B to B, ecommerce marketplace for all training needs, and related services. Our Platform and Services are hosted in AWS or Azure facilities.
What information do we collect?
WE DO NOT SELL YOUR PERSONAL INFORMATION. WE DO NOT GIVE ACCESS TO YOUR PERSONAL INFORMATION TO THIRD PARTIES EXCEPT TO SERVICE PROVIDERS/SUBPROCESSORS TO ASSIST US IN THE PROVISION OF OUR SERVICES TO YOU.
The Personal Information that we collect will be stored on our servers. Users are able to change their Personal Information via email by contacting us at email@example.com. We collect the following information when you register on our Website:
- Account Information: When you register, use our Website, access our Platform, or use our Services, we will collect your Personal Information. We may also collect information that does not personally identify you such as (i) your geolocation, and (ii) information about your internet connection, the equipment you use to access our Website, and (iii) usage details.
How do we collect information?
- Usage details;
- IP addresses;
- Information obtained through browser cookies;
- Information obtained through flash cookies;
- Web beacons on our Website;
- Web beacons on emails sent by us; and
- Other tracking technologies.
How do we use your information?
We use the information that you provide to:
- Provide Users with information, products, or services requested from us;
- Notify Users about changes to our Website and any products or services;
- Allow Users to participate in interactive features on our Website;
- Improve the Website;
- Improve our customer service;
- Anonymize data and aggregate data for statistics;
- Contact Users for other purposes with Users’ consent;
- Contact Users about our products and services that may be of interest; and
- Send User periodic emails, in accordance with the CAN-SPAM Act of 2003 as detailed in Section 13, via the email address provided by User to (i) send information, respond to inquiries, and/or other requests or questions; (ii) send additional information related to User’s product and/or service; and (iii) market to our mailing list.
We allow third party behavioral tracking and links to third-party web pages. Occasionally, at our discretion, we may include or offer third-party products or services on our Website. These third-party sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our Website and welcome any feedback at about these sites. Please contact us at firstname.lastname@example.org.
How do we protect information we collect?
Our Website receive regular security scans and penetration tests. Our Website also receive regular malware scans. In addition, our Website uses an SSL certificate as an added security measure. We require username and passwords for our employees who can access the Personal Information of Users that we store and/or process on our servers. In addition, we actively prevent third parties from getting access to the Personal Information of Users that we store and/or process on our servers. We will implement reasonable security measures every time you (a) enter or submit your information, and (b) access our Website. We transmit, transfer, and store your data in an encrypted format in secure servers behind firewall. Access to your Personal Information is restricted to our employees who have a legitimate business reason to access such Personal Information. We use a User Name and Password for those who do have to access such Personal Information.
Data Security Measures
- Security Measures: We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Website.
- Fair Information Practice Principles: In the event of a personal data breach, we will notify the User within 72 hours of becoming aware of the breach via (i) email and/or (ii) on our Website. We agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.
- Location of the Data Subject: We generally will not move Personal Information of European Union residents outside of the European Union. If we do, we will comply with the new Standard Contractual Clauses (the “New SCCs”), adopted by the European Union, which replaced the old Standard Contractual Clauses (the “Old SCCs”) and became effective on September 27, 2021.
Disclosure of Personal Information
- We do not sell, trade, rent, or otherwise transfer Personal Information to others, unless we provide you with advance notice. This does not include our hosting partners and other parties who assist us in operating our Website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential.
- We may disclose aggregated, de-personalized information about our Users that does not identify any individual to other parties without restriction, such as for marketing, advertising, or other uses.
- We disclose Personal Information to our subsidiaries and affiliates.
- We disclose Personal Information to contractors, services providers, and other third parties.
- We require all contractors, service providers, and other third parties to whom we disclose Personal Information to be under contractual obligations to keep Personal Information confidential and to use it only for the purposes for which we disclose them.
- We will disclose Personal Information in the event of a merger, sale of business, etc. to the successor in interest, who agrees to protect the privacy of such Personal Information.
- We require all other third parties, to whom we disclose Personal Information, to be under contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to such third parties.
- We disclose Personal Information to fulfill the purpose for which the User provided it.
- We disclose Personal Information for any other purpose for which the User provided it.
Other Disclosure of Personal Information
- We will disclose Personal Information (i) to comply with any court order, law, or legal process, including to respond to any government or regulatory request, (ii) to enforce or apply our Terms of Service and other agreements, (iii) if we believe it is necessary or appropriate to protect the rights, property, or safety of EdCast, our customers or others, and/or (iv) if it is necessary or appropriate to protect the rights, property, or safety of EdCast, our customers, or others, and this includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Choices Users Have About How EdCast Uses and Discloses Information
- Disclosure of Users’ Information for Third-Party Advertising or Targeted Advertising: Users can opt-out by emailing us their opt-out request at email@example.com. Users receiving promotional email can opt-out by sending a return email requesting to be omitted from future promotional email distributions. This opt-out will not apply to information provided by EdCast for product purchases, warranty registration, or other transactions.
Children’ Online Privacy Protection Act (OPPA) (For Children Under 13 Users Only)
The Children’s Online Privacy Protection Act (“COPPA”) is a federal legislation that applies to entities that collect and store “Personal Information,” as the term is defined under COPPA, from children under the age of 13. We are committed to ensure compliance with COPPA. Our Website is not meant for use by children under the age of 13. Our Website do not target children under the age of 13, but we do not age-screen or otherwise prevent the collection, use, and personal disclosure of persons identified as under 13. If you would like to know more about our practices and specifically our practices in relation to COPPA compliance, please email us at firstname.lastname@example.org.
IF YOU ARE UNDER 13, PLEASE DO NOT ACCESS OR USE OUR WEBSITE. WE WILL DE-REGISTER YOU WHEN WE FIND OUT THAT YOU HAVE REGISTERED AND ARE UNDER THE AGE OF 13.
Your California Privacy Rights
EdCast does not sell, trade, or otherwise transfer to third parties your Personal Information as the term is defined under the California Civil Code Section §1798.82(h) (“CCPA,” as amended by the California Privacy Rights Act “CPRA” and, with CCPA, collectively the “CCPA”)). Additionally, the CCPA permits Users of our Website, who are California residents to request certain information regarding our disclosure of their Personal Information to third parties for their direct marketing purposes. To make a request for such disclosure, or identification and/or deletion of Personal Information in all our systems that we store on you, please send an email to email@example.com or write us at EdCast Inc., 1901 Old Middlefield Way #21, Mountain View, CA 94043.
Note that (i) if we delete your Personal Information as requested, we will no longer be able to provide you access to Our Platform and our Services to you and (ii) we may need to keep such Personal Information for a while during the shutting down and billing process.
If you would like to discuss our Personal Information storage and processing process with us, please send an email to firstname.lastname@example.org or write us at EdCast Inc., 1901 Old Middlefield Way #21, Mountain View, CA 94043. See Section 11 below for other privacy rights for California residents under the California Consumer Privacy Act, which went into effect on January 1, 2020.
California Consumer Privacy Act
WE DO NOT SELL YOUR PERSONAL INFORMATION.
To know more about how your Personal Information is used, you can email us at email@example.com.
- Right to Request Personal Information: Upon request, we will provide you with (i) a list of all Personal Information that we have collected on you, (ii) from whom we obtained such Personal Information, (iii) the reason why we collected such Personal Information, and (iv) with whom (if any) we have shared such Personal Information.
We require such Personal Information to be able to provide our Services to you. Unless otherwise specified, we only collect Personal Information from you. We do not use others to provide us with your Personal Information.
- Disclosure of Personal Information: We only share your Personal Information with service providers, e.g., billing and collection agents, who enable us to provide our Services to you. We do not sell or give your Personal Information to third parties for purposes unrelated to our provision of Services to you.
- Right to have Personal Information Deleted: Upon request, we will delete all of your Personal Information that we have collected on you and will direct our Service Providers to also delete all of your Personal Information. But note that if we do delete all of this Personal Information, you will no longer be able to use our Services.
- Non-Discrimination Right: We will not discriminate against you for exercising any of your CCPA rights. We will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
- Financial Incentives: However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
- Sale of Personal Information; Under 16: We do not sell Personal Information at all. We will not sell your Personal Information if you are under the age of 16 unless we have the consent of your parent or your guardian nor will we sell it if you ask us not to do so. We do not sell any Personal Information.
- Opt Out Right: You may send the request to Opt Out (i) to firstname.lastname@example.org, (ii) by phone at our toll-free number 1-844-833-2278, or (iii) by writing to us at Privacy Officer, 1901 Old Middlefield Way #21, Mountain View, CA 94043.
- Personal Information that We Store: For your information, we store/collect the following Personal Information on you including your full name, work email address, company information, geolocation, and information about your internet connection, the equipment you use to access our Website, and usage details.
General Data Protection Regulation and SCCs
1. For European Visitors, Consumers, and Customers:
- If you are a resident of or a visitor to Europe, you have certain rights with respect to the processing of your Personal Data, as defined in the General Data Protection Regulation (“GDPR”).
- Please note that in some circumstances, we may ask you to provide us with additional information in connection with your request, which may be Personal Data, for example, if we need to verify your identity or the nature of your request.
- In such situations, however, we will still respond to let you know of our decision.
- As used herein, “Personal Data” means any information that identifies you as an individual, such as name, address, email address, IP address, phone number, business address, business title, business email address, company, etc.
2. U.S. Privacy Shield Certification: On July 16, 2021, the Court of Justice of the European Union (CJEU) invalidated the EU-US Privacy Shield Certification Program (the “Privacy Shield Program”). Prior to July 16. 2021, our transfer of Personal Data from the EU to the US for processing was covered by our Privacy Shield Certification with the United States (“US”) Department of Commerce (the “US DOC”) and the EU Standard Contractual Clauses (“Old SCCs”) promulgated by the EU for transport of Personal Data from the EU to countries other than the US for processing. Notwithstanding the invalidation of the Privacy Shield Program, we will continue to adhere to the Privacy Shield Program Principles with respect to the transport of Personal Data from the EU to the US for processing.
4. The New SCCs:
- The New SCCs took effect on June 27, 2021.
- The Old SCCs may still be used for new data transfers in new contracts during a three-month transition period that ends on September 27, 2021.
- Existing data transfers contracts that rely on the Old SCCs can be used until December 27, 2022, by which time all data transfers relying on the Old SCCs must be transitioned to the New SCCs.
- As of now, we and our customers are using the New SCCs to transport Personal Data from the EU to other countries including the US for processing by us.
- You are the Controller, as defined in the GDPR, and the Exporter, as defined in the New SCCs, of the Personal Data and we are a processor, as defined in the GDPR, and the Importer of such Personal Data.
- You agree to comply with the GDPR rules that apply to Controllers and the New SCCs rules that apply to Data Exporters. We agree to comply with the GDPR rules that apply to Processors and the New SCCs rules that apply to Data Importers.
5. Our GDPR Compliance Commitment:
- We agree to fully comply with the letter and the spirit of the GDPR and the New SCCs with respect to the transfer or your Personal Data for Processing outside the EU.
- As a Data Importer, a User may contact us as set forth in Subsection 6 below with respect to the Personal Data we store and process on you.
- We hereby notify you that we will be processing, as defined in the GDPR, the Personal Data of your Authorized Users (i.e., those individuals whom you have authorized to access our Platform and to use our Services) in the US and India for us to be able to provide the Services to you that we have agreed to do in our definitive service agreement between you and us.
- Upon request, we will provide you with a list of your Personal Data that we will process and a copy of the New SCCs under which we will transport your Personal Data for processing.
- We hereby warrant that, at the time of agreeing to the SCCs for the transport of your Personal Data, we have no reason to believe that the laws and practices applicable to us as a data processor and a data importer, including those of the US and India, are not in line with the requirements of the New SCCs.
- If we cannot satisfy any request or dispute to your satisfaction, we will agree to arbitrate or litigate the dispute in the EU jurisdiction in which your reside.
- We will only transfer your Personal Data to a third country in accordance with documented instructions from you.
- Your Personal Data will be transferred and stored in an encryption format.
- Only our employees, who have a need to access your Personal Data to enable us to meet our contractual and legal obligations to you, will be given access to your Personal Data.
- Such employees will be given a User Name and Password to access your Personal Data.
- We will retain your Personal Data for as long as we need it to fulfill our obligation to you or as required by applicable law.
- We will delete y our Personal Data if we no longer need it or as required by applicable law.
- You may ask to delete your Personal Data at any time and we will do.
- We will keep an automated record of all persons who have accessed your Personal Data.
- Access: You can request at any time information about the Personal Data we hold about you.
- Copy of Personal Data: You can at any time request a list of the categories of Personal Data we maintain or a copy of the Personal Data.
- Rectification: If you believe that any Personal Data that we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.
- Direct Correction: You can also correct some of the Personal Data directly by logging into your service account. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.
- Objection: You can contact us to let us know that you object to the collection or use of your Personal Data for certain or any purposes.
- Erasure: You can request that we erase some or all of your Personal Data from our systems.
- Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
- Portability: You have the right to ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another entity where technically feasible.
- Withdrawal of Consent.: If we process your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, it may limit your ability to use some/ all of our Services and you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
- Right to File Complaint: You have the right to lodge a complaint about our practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. Please go to https://ec.europa.eu/justice/article-29/structure/data-protection- authorities/index_en.htm to locate your Data Protection Authority.
Can-Spam Act Of 2003
The CAN-SPAM Act establishes requirements for commercial messages, gives recipients the right to have businesses stop emailing them, and spells out penalties for violations. Per the CAN-SPAM Act, we will:
- not use false or misleading subjects or email addresses;
- identify the email message as an advertisement in some reasonable way;
- include the physical address of EdCast Inc., which is 1901 Old Middlefield Way #21, Mountain View, CA 94043;
- monitor third-party email marketing services for compliance, if one is used;
- honor opt-out/unsubscribe requests quickly; and
- give an “opt-out” or “unsubscribe” option.
If you wish to opt out of email marketing, follow the instructions at the bottom of each email or contact us at email@example.com and we will promptly remove you from all future marketing correspondences.
If you have any questions regarding this Section, please email us at firstname.lastname@example.org.
List Of Third-Party Service Providers
EdCast uses the following third-party service providers/Subprocessors, as defined in the GDPR, for the provision of services as detailed under the Terms of Service.
Name of Third-Party Service Provider
Address: 410 Terry Avenue North, Seattle, WA 98109-5210
Telephone: (855) 817-0841
2624 NE University Village St, Seattle, WA 98105
Additionally, if you have any questions or concerns about our third-party service providers, please email us at email@example.com.
Copyright Infringement/DMCA Notice
If you believe that any content on our Website violates your copyright, and you wish to have the allegedly infringing material removed, the following information in the form of a written notification (pursuant to the Digital Millennium Copyright Act of 1998 (“DMCA Takedown Notice”)) must be provided to our designated Copyright Agent.
- Your physical or electronic signature;
- Identification of the copyrighted work(s) that you claim to have been infringed;
- Identification of the material on our Website you claim is infringing and that you request us to remove;
- Sufficient information to permit us to locate such material;
- Your address, telephone number, and email address;
- A statement that you have a good faith belief that use of the objectionable material is not authorized by the copyright owner, its agent, or under the law; and
- A statement that the information in the notification is accurate, and under penalty of perjury, that you are either the owner of the copyright that has allegedly been infringed or that you are authorized to act on behalf of the copyright owner.
EdCast’s Copyright Agent to receive DMCA Takedown Notices is Copyright Designated Agent, firstname.lastname@example.org, at EdCast Inc., Attn: DMCA Notice, 1901 Old Middlefield Way #21, Mountain View, CA 94043. You acknowledge that for us to be authorized to take down any content, your DMCA Takedown Notice must comply with all the requirements of this Section. Please note that, pursuant to 17 U.S.C. § 512(f), any misrepresentation of material fact (falsities) in a written notification automatically subjects the complaining party to liability for any damages, costs and attorney’s fees incurred by EdCast in connection with the written notification and allegation of copyright infringement.
– Privacy Officer
– Email: email@example.com
– Address: EdCast Inc., 1901 Old Middlefield Way #21, Mountain View, CA 94043