Privacy Policy COLĒGIA
Effective as of October 8, 2020

We at Academica Virtual Education LLC (“Company,” “we,” “us,” or “our”) created this privacy policy (“Privacy Policy”) to provide you with information on how the information you provide to us is used and shared on our COLĒGIA platform and website. This Privacy Policy relates to the information collection and use practices of Company in connection with our COLĒGIA platform, website, and services (the “Services”), which are made available to you through the COLĒGIA website (the “Site”). We strive to educate parents and kids about how to appropriately safeguard their privacy when using our Services. We are committed to complying with the Children’s Online Privacy Protection Act of 1998 (“COPPA”), which requires us to inform parents and legal guardians about our information collection and use practices. COPPA also requires that we obtain parental consent before we allow children under the age of 13 to access and/or use our Services. We urge kids to check with their parents before entering information through our Site and/or Services, and we recommend that parents discuss with their kids restrictions regarding the online release of Personal Information (as defined below) to anyone they don’t know.
By visiting our Site and/or using our Services, or by permitting your child to use our Services, you are agreeing to the terms of this Privacy Policy and the accompanying Terms of Service. Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Terms of Service.

Information We Collect

1. Personal Information.
We do not collect any personal information from you unless you voluntarily provide it to us. When you sign up to become a user of the Site (a “User”), you will be asked to provide us with certain personal information, such as your first name, last name, and e-mail address. In this Privacy Policy, we refer to this information as “Personal Information.” Other than the online contact information required to obtain parental consent, we do not collect any Personal Information from Users under the age of 13 unless the User’s parent or legal guardian has first provided us with consent for that User to use the Services and disclose Personal Information to us. If you are a User under the age of 13, please do not send any Personal Information to us if we have not obtained prior consent from your parent or guardian. If we learn we have collected Personal Information from a User under the age of 13 without parental consent, or if we learn a User under the age of 13 has provided us Personal Information beyond what we request from him or her, we will delete that information as quickly as possible. If you believe that a User under the age of 13 may have provided us Personal Information in violation of this Privacy Policy, please contact us at info@colegia.org.

2. Usage Information.
Like most platforms, we use automatic data collection technology when you visit the Site to record information that identifies your computer, to monitor and track your use of our Site, and to collect certain basic information about you and your surfing habits. This information includes information about your operating system, your IP addresses, browser type and language, referring and exit pages and URLs, keywords, date and time, amount of time spent on particular pages, what sections of a website you visit, and similar information concerning your use of the Site and the Services (the “Usage Information”).
We collect this Usage Information by using cookies and pixel tags (also called web beacons or clear gifs). Cookies are small packets of data that a website stores on your computer’s hard drive so that your computer will “remember” information about your visit. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of website users. You can reject cookies by following the directions provided in your Internet provider’s “help” file. If you reject cookies, you may still visit the Site, but may not be able to use some areas of the Site and/or the Services.
We also collect Usage Information regarding any information or communications a user enters or transmits into our platform. E-mails sent and received and other activities on the platform and on third-party platforms linked to our platform may be monitored by us for safety purposes to ensure that users are complying with our Acceptable Use Policies and other aspects of our Terms of Service. We do not collect Personal Information in this way, but if you’ve provided us with Personal Information, we may associate that information with the information that is collected automatically. Automatic data collection may be performed on our behalf by our services providers.

If you choose to purchase or subscribe to a feature or Service of Company that requires a payment (such as if you obtain products or services via one of our third party providers on the COLĒGIA platform), you may be required to provide us with your payment information, including, without limitation, bank account numbers, credit card or debit card numbers, account details, ACH information, and similar data (collectively, “Payment Information”).

Google Analytics. We use the Google Analytics platform to collect and process your Usage Information and assess how users are using the Site. Google Analytics uses “cookies,” which are text files placed on your computer that are used to collect Internet log information and visitor behavior information in an anonymous form. Information generated by the cookie about your use of the Site is transmitted to and stored by Google on servers in the United States. Google will use this information to evaluate your use of the website, compile reports on website activity for website operators, and provide other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. By using the Site, you consent to the processing of data about you by Google in the manner and for the purposes set out above. You can delete cookies already set by Google Analytics, or prevent Google Analytics from recognizing you on return visits to this site, by disabling cookies in your Internet browser. You can find more information about Google’s applicable privacy regulations by visiting https://policies.google.com/privacy?hl=en.

3. Registration and Authentication
We may use a contact form to register and authenticate Users as well as to reply to requests for information, quotes, or any other request as generated by the form’s header. Personal Data Processed: e-mail address, first name, last name. Category of personal data collected according to CCPA: identifiers. We also use third-party registration and authentication services to help identify student users, parent users, and other users and give them access to Services. In these cases, we will receive access to some of your data stored by these third-party services to facilitate the above purposes. The third-party applications we use for this purpose, and how these applications are used, are outlined below: Facebook Authentication Facebook Authentication is a registration and authentication service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on the location this Application is accessed from, and is connected to the Facebook social network.
Personal Data processed: Basic User Data (ID, name, picture, gender, locale, public data, user E-mail address, other types of Data as specified in the privacy policy of the service. Place of processing: United States (Privacy Policy); Ireland (Privacy Policy). Category of personal data collected according to CCPA: internet information. This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers. Google OAuth and Gmail Permissions to Access User Data Google OAuth is a registration and authentication service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from, and is connected to the Google network. Personal Data processed: various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield participant. Category of personal data collected according to CCPA: internet information. Furthermore, to provide the Services, we use restricted scopes for Gmail which allow access to User data related to this Google service (as indicated below). This access is provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from, under strict terms. Here's what this means for such User data:
  • The use of User data is limited to providing or improving User-facing features. User data will not be used for serving ads, including retargeting, personalized, or interest-based advertising.
  • User data will be transferred to third parties only if necessary, to provide or improve User-facing features and as necessary to comply with applicable law or as part of a merger, acquisition, or sale of assets with notice to Users.
  • Humans will not read the data unless:
    • the Owner has obtained the User's affirmative agreement for specific messages;
    • it is necessary for security purposes and/or to comply with applicable law, or;
    • the use is limited to internal operations and the data (including derivations) have been aggregated and anonymized.
Personal Data processed: Basic settings management; Full access. Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Privacy Shield participant. Category of personal data collected according to CCPA: internet information. This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers. Sign in with Apple (Apple Inc.) Sign in with Apple is a registration and authentication service provided by Apple Inc. In cases where Users are required to provide their email address, Sign in with Apple may generate a private relay address on behalf of Users that automatically forwards messages to their verified personal email account - therefore shielding their actual email address from the Owner. Personal Data processed: email address; first name; last name. Place of processing: United States – Privacy Policy. Category of personal data collected according to CCPA: identifiers. This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

4. How We Use Your Information.
We may use your Personal Information and Usage Information in a manner that is consistent with this Privacy Policy and the context of our relationship with you. We will use your Personal Information and Usage Information collected through the Site for the following purposes:

(a) To identify you when you sign in to your account;
(b) To respond to your requests and to provide you with the Services;
(c) To respond to your inquiries and contact you about changes to the Site and/or the Services;
(d) To send you notices (for example, in the form of e-mails, mailings, and the like) regarding products or services you are receiving, and for billing and collection purposes;
(e) To send you information we think you may find useful or that you have requested from us;
(f) To enhance and improve the Site or the Services, such as through personalized features and content;
(g) To analyze the use of the Site and the Services and the people visiting to improve our content and Site and the Services;
(h) To investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our policies, or as otherwise required by law;
(i) For any other purposes disclosed at the time the information is collected or to which you consent; and
(j) As otherwise specifically described in this Privacy Policy.
We may use your Payment Information to process your authorized payments for our Services.

Microsoft Cloud Storage. Student documents that are submitted on the Colegia platform will be sent to Microsoft's cloud storage server to enable preview in its user interface. This data cannot be accessed by anyone unless a person is signed into the Colegia server and has been given the right to access the student submission (i.e., the student or the student's parent/guardian, teacher, or school administrator).

5. Disclosure of Personal Information to Third Parties.
We do not disclose your Personal Information to third parties for their direct marketing purposes.
We, like many platforms, sometimes hire other companies to perform certain platform-related functions. Examples include mailing information, maintaining databases, hosting services, processing payments, and third-party-provided scheduling, e-mail, and virtual classroom platforms. When we employ another company to perform a function of this nature, we may provide them with the information that they need to perform their specific function, which may include Personal Information.
If we or all or substantially all of our assets are acquired, we expect that the information that we have collected, including Personal Information, would be transferred along with our other business assets.
We may disclose your Personal Information and Usage Information to government authorities and to other third parties when compelled to do so by government authorities, at our discretion, or otherwise as required by law, including but not limited to in response to court orders and subpoenas. We may also disclose your Personal Information and Usage Information when we have reason to believe that someone is or may be causing injury to or interference with our rights or property, other users of this Site, or anyone else that could be harmed by such activities.
We may share your Payment Information with a third-party service provider as necessary to process your payment. The third-party service provider stores your Payment Information; we do not store this information. Storage by the third-party service provider of your Payment Information is subject to the privacy policies and practices of the third-party service provider and is not subject to the terms of this Privacy Policy. By providing your Payment Information, you acknowledge and agree to use of such information by the third-party service provider for purposes of processing your payment to us.

6. How We Protect Your Information.
We take commercially reasonable steps to protect the Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

7. Accessing and Modifying Account Information.
You may update the information that is stored in your user account by visiting info@colegia.org or by e-mailing us at info@colegia.org.
We strive to help parents ensure that their kids have a safe experience using our Services. Parents or legal guardians can request to review any Personal Information collected about their child under 13 years of age, have this information deleted, request that there be no further collection or use of their child’s Personal Information, and/or allow for our collection and use of their child’s Personal Information while withholding consent for us to disclose it to third parties. We take steps to verify the identity of anyone requesting information about a child and to ensure that the person is in fact the child’s parent or legal guardian.

8. Your Choices.
If you wish to stop receiving promotional e-mails, you may do so by e-mailing info@colegia.org. You may also choose to unsubscribe from our e-mails by following the instructions in the bottom of the email.

9. Links.
The Services contain content, services, icons, text, and other materials that link to websites, platforms, applications, and resources operated by third parties. We have no control over those other sites, and this Privacy Policy does not apply to them. Please refer to the privacy policies of those sites for more information on how the operators of those sites collect and use your Personal Information.

10. California Privacy Law: Do Not Track.
We do not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.

11. Important Notice to Users Outside the U.S.
The Site and the Services are operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By providing us with any information through the Site or the Services, you consent to this transfer.

12. Changes to This Privacy Policy.
This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time and will post any changes on the Site as soon as they go into effect. By accessing the Site or using the Services after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer back to this Privacy Policy on a regular basis.

13. How to Contact Us.
If you have questions about this Privacy Policy, please e-mail us at info@colegia.org, with “PRIVACY POLICY” in the subject line.