Schedule B – Privacy Statement

 

We at Clockwork Fox, Inc. (“Clockwork Fox”) know that you care about how your personal information is used and shared, and we take your privacy seriously. By accessing or using the Services (as defined in the Terms of Service), you acknowledge that you accept and consent to the practices and policies outlined in this Privacy Policy.

Remember that your use of Clockwork Fox’s Services is at all times subject to the Terms of Service, which incorporates this Privacy Policy. Any terms we use here without defining them have the definitions given to them in the Terms of Service.

Please read on to learn more about how we collect and use your information; if you have any questions or concerns regarding our privacy practices, please send us a detailed message to info@zorbitsmath.com, write us at 34 Harvey Road, Suite 202, St. John’s, NL, Canada, A1C 2G1, or call us at 1(709) 722-0140.

 

What information we collect

The information that we collect can be broken down into three broad categories:

  1. Information that you, as an administrator, teacher, or parent, provide to us;
  2. Information that we automatically collect as a result of your use of the Services;
  3. Information we automatically collect from students who play the Zorbit’s Math Adventure games.

 

Here’s a breakdown of what each of those how, why we collect the information, and how we use it.

1. Information that you, as an administrator, teacher, or parent, provide to us;

 

When an administrator, teacher, or parent signs up or receives an account for our Services, we will ask for a number of items of information. Here’s what they are and how we use them:

  • Email Address. This is your login username to access the Services. See the Terms of Services for the types of things we send to your email address, and to see which forms of email you can opt out of. For educators, your email address also helps us identify which district you belong to.
  • Phone number. If you “request a demo” online, you will be asked to enter a phone number. We will use this phone number to call you to set up a time for the demo. It may also serve as a means of contacting you about important account information, such as account expiry.
  • Student names. Teachers may enter the names of their students manually. A username and password for the student will be automatically generated. This name will appear on reports and functions on the dashboard. Only the first name and first initial of the last name are required. (Note: Entering names manually is not required for any districts using the third-party service Clever. See below for more on Clever.)
  • Credit card information (Parents only). Parents are required to pay by credit card. This information will be stored within the third-party service we use to process online payments called Stripe.

 

2. Information that we automatically collect as a result of your use of the Services;

 

Here is information we collect automatically for account owners (e.g. Administrators, Teachers, Parents):

  • We may collect details of interactions that you have with us, for example, through your interactions with our customer and technical support teams.
  • We collect information on your general account activity – the elements our Services that you are using, and the frequency at which you use them. We do this so we can learn about how people are using our services. For example, if we see that not many people are using the Teaching Activities on the Teacher Dashboard, then that tells us that we probably need to do a better job of highlighting where these tools are and how to use them.
  • We also use third-party analytics software to allow us to better understand the functionality of our mobile and web applications. This software may record information such as how often you use the applications, the events that occur within the applications, aggregated usage information, performance data, and where the application was downloaded/accessed from.

 

3. Information we automatically collect from students who play the Zorbit’s Math Adventure games.

 

We also collect information directly from your students’ interactions with the Zorbit games. Collectively, we call this information “Game Data”. We collect this information for three purposes:

  • To deliver activity and performance data to administrators, teacher, and parents, on their respective dashboards;
  • To be analyzed by our adaptive learning system, which will adapt the game content to each student in an effort to provide them with math material that lies within their zone of proximal development;
  • To improve our product. For example, if we notice that student scores are particularly low on one or two activities – it may indicate to us that that activity is too hard. Or, if we notice that a particular area of the game is getting less visitors than others, it might tell us that students don’t find that particular storyline very engaging.

 

What we will do with your information 

The information collected from Registrants, customers or prospective customers may be used for the following purposes:

  • to provide access to our products and services, or to provide quotes or offers for, and updates about, our products and services;
  • to send a confirmation notice to the Registrant of the registration;
  • to administer and manage accounts, including password resetting, responding to questions raised by Registrants, to contact the Registrant about any problems with the Registrant’s account or conduct on the Site;
  • to send out notifications or emails about the Site including information about current events, changes, improvements, upgrades, and rules of the Site;
  • for administrative, planning, product or service development, quality control and research purposes relating to our products and services;
  • for marketing purposes, but only where we have express or implied consent to contact someone or we are otherwise permitted by law to do so. Registrants may also opt out at any time by following the specific opt out instructions within the communications that we send.

What we will not do with your personal information

Clockwork Fox will keep your personal information confidential and not sell or knowingly divulge your information to advertisers or any external third parties, unless:

  • we believe, in good faith, that we are required to share your information with a third party in order to comply with law, regulation, legal process, court order or subpoena;
  • to enforce our Terms of Service;
  • the disclosure is to a third party that acts on our behalf, such as a distributor of our products and services;
  • in connection with any transaction involving our companies or assets, where another party acquires ownership or operation of the Site, in which case that successor organization will be subject to this Privacy Policy; or
  • to protect the safety and security of our Registrants and our Site.

If third parties act on our behalf, we require them to hold, use and disclose your personal information in accordance with this Privacy Policy and applicable privacy obligations.

Generally we will only use your information within Clockwork Fox, however, sometimes we provide data on results to government education departments, organizations managing or representing schools, or schools themselves, especially in the case of School Customers, who use the features of our products (such as performance reporting tools) for educational / teaching purposes. We will require these third parties to comply strictly with our instructions and we will require that they not use the data for commercial purposes.

 

How we collect and process your information

We may collect your personal information in a number of ways, including:

  • directly from you (unless it is unreasonable or impracticable to do so);
  • from our school / educational institution customers (e.g. teachers or school administrators that purchase access to our Site for their students and teachers); or
  • from third parties such as our distributors (resellers and sales agents) or third party services such as Student Information Systems or Clever.

Parents registering on behalf of their child(ren), must give their consent at the time of registration to provide us with information about them and their child(ren).

Teachers or administrators registering for their class or school must give their consent at the time of registration to provide us with their own name, class name, school name and their email address, as well as the names of their students.

We also ask for Registrants’ consent to use any personal information collected in accordance with this Privacy Policy at the time of login to our Site. If a Registrant does not wish to provide us with their consent, they cannot agree to the Site Terms and Conditions and must not use the Site.

How long we hold your information

We retain the personal information that we collect from and about our Registrants for as long as it is needed to provide access to the Site or to manage that Registrant’s account. We take reasonable steps to delete the personal information we collect if your registration to use our Site lapses and you opt out of receiving further communications from us, or if you ask us to delete your information. We may however retain and use personal information as necessary to comply with our legal and regulatory obligations, to resolve disputes and to enforce our agreements, and we may retain and use anonymous and aggregated information for performance reporting, benchmarking and analytic purposes and for product and service improvement.

Student Data will always be deleted within one year after the end of a paid term of use, or sooner if requested by the purchasing institution. Registrants can request that their personal information be deleted any time by contacting the Clockwork Fox at info@zorbitsmath.com.

Keeping your personal information secure

Your Clockwork Fox account Personal Information or Children’s Personal Information is protected by a password for your privacy and security, as well as by numerous other technical, administrative, and physical security mechanisms. We also use coding practices that take steps to prevent attacks on our Services from web browsers and malicious scripts, by processing all actions through several permission verifications checks.

You may help protect against unauthorized access to your account and Personal Information or Children’s Personal Information by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your account.

For parents, when you enter sensitive information (such as a credit card number) in our Credit purchasing process, we encrypt the transmission of that information using secure socket layer technology (SSL).

Clockwork Fox endeavors to keep your information private; however, we cannot guarantee security. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information. For additional information about the security measures we use in connection with the Services, please contact us at info@zorbitsmath.com.

Currently, all software and data associated with Zorbit’s Math Adventure is stored in Canada with Amazon Web Services (AWS). If you are visiting from the European Union or other regions with laws governing data collection and use that may differ from Canadian law, please note that you are transferring your personal data to Canada, which does not have the same data protection laws as the EU or other regions; by providing your personal data you consent to the use of your personal data for the uses identified above in accordance with this Privacy Policy and the transfer of your personal data to Canada as indicated above.

If you are based in the United States and are concerned that our data collection measures do not comply with your state’s requirements, please contact us at info@zorbitsmath.com. If you are interested in our Services, we would be happy to work with you to ensure our policies comply with those of your district/school.

Anonymous or aggregated information

In addition to personal information and results data, Clockwork Fox also collects anonymous information about Registrants and the activities of Registrants on the Site. Anonymous information is information that is not linked to the name or identity of a user. This information is used for educational performance reporting and analytics and to assist us in enhancing the learning resources. The information remains anonymous at all times. 

Clockwork Fox utilises third-party providers to power certain elements of the Company’s online marketing and advertising. These service providers collect data about your activities that does not personally or directly identify you when you visit our website or the websites and online services where we display advertisements (i.e. publishers). This information may include the content you view, the date and time that you view this content, the products you purchase, or your location information associated with your IP address. We use the information we and these third party service providers collect to serve you more relevant advertisements regarding Clockwork Fox resources (referred to as “retargeting”). We collect information about where you saw the ads and what ads you clicked on. This is data that does not personally or directly identify you.

When agreeing to the Terms and Conditions, Registrants grant us the right to use this anonymous information for our own purposes, such as the preparation of statistical reports or to change the content of our products.

 

Cookies

A cookie is a little piece of information handed to a web browser from a web server that contains information that can be retrieved from the server later. When you visit the Site the server may attach a cookie to your computer’s memory. Clockwork Fox uses cookies only to the limited extent to recognise the Registrant when they visit the Site and pairing that Registrant with the account (and account preferences) that the Registrant created. We use cookies to better display our website, to save you time, to provide better technical support and to track website usage. For example, cookies help us to:

  • Keep track of whether you are signed in or have previously signed in so that we can display all the features that are available to you;
  • Remember your settings on the pages you visit, so that we can display your preferred content the next time you visit;
  • Customise the function and appearance of the pages you visit based on information relating to your account; for example, in order to default you to a particular grade level, or to remember customised settings for a report.

However, this information is not linked to any personal information that Registrant may provide and cannot be used to identify Registrants.

 

Your Information and Third Parties

Except as provided in this Privacy Policy, Clockwork Fox WILL NOT disclose the information that it obtains from you to third parties without your express written permission, or where we believe, in good faith, that the law requires us to disclose the information. If you request that Clockwork Fox share any information provided by or collected from you (or in the case of School Customers, your student users) directly with a third party designated by you, then you agree that you (and not Clockwork Fox) will be solely responsible for the use, storage, and maintenance of such information by such third party.

Clockwork Fox WILL NOT sell, trade, or assign any unaggregated personal information that it collects to third parties outside of Clockwork Fox. We, however, may aggregate the information that we collect from users of our website to create demographic profiles and performance profiles regarding the progress of students who use the Programs. Clockwork Fox may share aggregated information with marketing professionals or potential investors. This aggregated information will be compiled and reported in the form of ANONYMOUS group statistics only in such a manner that makes individual student users unidentifiable. In addition, in order to offer and improve the Programs, Clockwork Fox may share Registration Information about the parents, legal guardians, and school officials that register to participate in the Programs, along with such registrants’ Participation History, to contractual business partners of Clockwork Fox that are directly involved in the sale, distribution, operation, maintenance, and support of the Programs on behalf of Clockwork Fox.

Notwithstanding anything to the contrary, as Clockwork Fox continues to develop its business, it might sell some or all of its assets. In such transactions, customer information is generally one of the transferred business assets. An acquiring company would be required to protect all information that Clockwork Fox collects from users of our website and Programs in accordance with the terms of this Privacy Policy. In the event of the acquisition of Clockwork Fox, Registrants will be sent a notification via email, giving them 30 days to opt out of the transition of data to the acquiring company.

Clockwork Fox will never send you unsolicited third-party promotional emails.

 

Revision of Privacy Policy

Clockwork Fox reserves the right to change, modify, or revise this Privacy Policy in order to comply with any applicable laws, to reflect changes in our processes or for any other reason at any time. Material changes in our Privacy Policy will be communicated to Registered Users and customers, but we also encourage our Registrants to check the Privacy Policy periodically to read about any changes, modifications, or revisions. Registrants may wish to check it each time they submit personal information. You will be deemed to have consented to such variation by your continued use of the Site following any changes being made.

 

Last modified July 31, 2018

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