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August 13

Privacy Policy

Classo

PRIVACY POLICY
(Last updated on January 12, 2020)

Classo is committed to protecting your personal information. The purpose of this Privacy Policy (the "Policy") is to inform you about our privacy and privacy practices, including how we collect, use and disclose your personal information.

The expression "Personal Information" refers to data relating to an identified or identifiable individual, subject to more specific definitions under applicable law. This Policy applies to all of our activities, including our Website, available at https://classo.org/, and where applicable the associated mobile applications (collectively, the "Website"), the platform that facilitates the search for digital educational resources and guide the decision-making process, the support-advice service, and a blog and newsletter service. The Website and the various services are collectively referred to as "Services".

Please read this Policy carefully. By providing us with your Personal Information (via our Website, via our social media accounts, by email, in person, or by telephone), by registering or using the Services, you consent to us collecting, using, and disclosing your Personal Information as set forth in this Policy, which may be amended from time to time.

This Policy is incorporated and subject to our other applicable terms and conditions, such as the terms of use of our Website. In this Policy, terms beginning with a capital letter, but not defined, have the meanings given to them in the above terms.

WHAT IS COVERED BY THIS POLICY?

Your consent to the collection, use, and disclosure of your Personal Information
What type of Personal Information we collect
How we use your Personal Information
How we share your Personal Information
Retention of Personal Information
Information security
Unsubscribe from communications
Rights regarding your Personal Information
International transfer and storage of data
Websites and third-party services
Data concerning children
Policy updates
Contact us

YOUR CONSENT TO THE COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL INFORMATION

We collect, use, and disclose your Personal Information with your consent or as permitted or required by law. For example, where your consent is not required, under the General Data Protection Regulations ("GDPR"), The legal basis for the treatment of Personal Information may be based on the fact that the processing of Personal Information is necessary for the service provided or for our legitimate interests, which are explained in more detail below. How we obtain your consent (i.e. the form we use) will depend on the circumstances, as well as the sensitivity of the data collected. Subject to the applicable provisions, your consent may be explicit or implicit, depending on the circumstances and the sensitivity of the Personal Information in question. If you choose to provide us with Personal Information, we understand that you consent to the collection, use, and disclosure of your Personal Information as set out in this Policy.

Generally, we ask for your consent when collecting your Personal Information. In the event that we wish to use your Personal Information for unidentified purposes at the time of collection, we will ask for your consent before using this data for this new purpose.

You may withdraw your consent to the collection, use, or disclosure of your Personal Information at any time by using the contact details in the "Contact Us" section below. However, before implementing the right to withdraw your consent, we may require proof of identity. In some cases, withdrawing your consent may result in us being unable to provide you with certain Services.

If you provide us with Personal Information about another person, you are responsible for obtaining that person's consent for us to collect, use, and disclose their data in accordance with this Policy.

WHAT TYPE OF THE PERSONAL INFORMATION WE COLLECT

In general, when you access, visit, or use our Services, we may collect the following data:

User of the Services (teachers, educational services professionals, ICT managers or school principals, administrators):

"Contact us" section: We can collect your name, your email address, the subject of your request for contact and the content of the message sent to us.

"Mailing List" and/or "Newsletter Subscription" section: We may collect your email address and other data (such as your name, surname, school name, name of the school board, topics, subject matters, grade levels, and position) that you submit when you sign up to receive Classo's newsletter, updates on Services, and other communications from us on our Website.

"Share your Opinion" and "Feedback" section: We can collect all the information you write in your message about the Classo platform, including first name, last name, subjects taught, grade levels taught, and the name of the school.

"Plan an appointment with the team" section: In addition to the date and duration of the desired appointment, we collect your last name, first name, email address, and the name of your company or organization.

"Create an account" section: When you complete your profile, we ask you for information about your role (teacher, director, educational advisor, etcetera.), the topics involved, the grade levels, the types of students targeted, the technological devices used, and the platforms available.

"Log in": We collect your email address and password, which is stored in encrypted form to make it unreadable.

"Pedagogical Usage Suggestion": We can collect all the information you write in your message, and publish your first name, last name, topics taught, grade levels taught, as well as the name of your school with your message.

"Comments" section on our blog (on the Website): We also collect all the information you write in a comment on an article on our blog.

Publishers of Digital Resources

Contact information: We can process your first name, your last name, your email address, the company name, and your phone number.

We may also collect information that, as the case may be, may be considered non-personal information, such as:

Description of the resource: We collect the name/title of the resource; the address of the website; the location of the head office (Quebec, other Canadian province, United States, France, other); description in French and in English of the resource; the type of resource proposed; whether it is free or paid; details of prices and licenses, if any; links to where the resource is available; types of devices on which the resource may be used; and operating systems supported.

Target users: We collect the school topics covered, the skills developed, the appropriate grade levels, and the appropriate type of teaching strategy (workshop, course work,...).

Support and additional documentation: We want to know if a guide, a tutorial, and/or technical support are available. We also want to know the benefits of using your resource, including research results or testimonials concerning the effectiveness of the resource, presence of advertising, availability of the resource for download from the Classo platform.

Data from other sources: We may obtain data, including Personal Information, from third parties and from non-Services sources, such as our partners, schools and school boards, third-party service providers, or advertisers. If we combine or associate data from other sources with Personal Information that we collect through the Services, we will treat the combined data as Personal Information in accordance with this Policy.

Automatically collected data If we use cookie data or similar technologies, we may use cookie data or similar technologies to identify your computer or mobile device and record your preferences and other data. We may use cookie data or similar technologies to evaluate the use of our Services, devices, or applications, in order to constantly improve our products, Services, and applications, to make recommendations, and to carry out transactions you've requested. Data from cookies or similar technologies may be stored locally on mobile devices or on computer servers operated or controlled by our third-party service providers. In addition, when you visit our Website, our systems automatically collect your IP address and the type of browser you use. We may use third-party service providers, such as Google Ads, to place advertisements on our products and Services on other websites. The use of cookies or other similar technologies by these third parties is governed by their privacy policies. You may limit the automatic collection of certain information on our Website by disabling cookies using your browser options. Be aware that disabling cookies may prevent you from using certain features of our Website.

We do not collect, process or store payment data, and more generally we do not process any data relating to the payment of the license for the chosen resource(s) once our Website links to the website of the resource chosen. We will not ask for any sensitive data, such as your health, ethnicity, religion, or sexual orientation. Do not send us such sensitive data, whether through our Website, our social media accounts, by email, in person, or over the phone.

HOW WE USE YOUR PERSONAL INFORMATION

We may use your Personal Information and other data for the purposes described below. In each case, we identify the rationale for using your Personal Information:

• Provide you Services and help you use the Services. Applicable legal basis: performance of the contract;

• Contact you regarding the Services. Applicable legal basis: consent;

• Supervise and improve the Services, as well as develop new products and services. Applicable legal basis: legitimate interest;

• Perform research and analysis related to our company and our Services. Applicable legal basis: legitimate interest;

• Answer questions and other requests. Applicable legal basis: performance of the contract;

• Collect notices and comments regarding the Services. Applicable legal basis: legitimate interest (to enable us to improve our Services);

• Provide you with information that may be of interest to you in connection with our Services. Applicable legal basis: consent; and

• Investigate legal claims or comply with our legal obligations. Applicable legal basis: legal obligation.

We may use your Personal Information for purposes other than those for which we obtained your consent, if such other purposes are permitted or required under applicable law.

HOW WE SHARE YOUR PERSONAL INFORMATION

Whenever possible, while we try to avoid sharing your Personal Information with third parties, we have defined below the cases for which such sharing may occur.
We may use and disclose your Personal Information when we believe that such use or disclosure is authorized, necessary, or appropriate:

• under applicable law, including laws outside your country of residence;

• to comply with court procedures;

• to respond to requests from public and governmental authorities, including public and governmental authorities outside your country of residence;

• with schools, school boards and publishers who present their educational resources on the platform to enforce the terms of the agreements for our Services;

• to protect our business or that of our affiliates or subsidiaries;

• to protect our rights, privacy, security, and property, and/or those of our affiliates, those of our users, and those of others; and

• to enable us to implement the remedies available or to limit the damage we may suffer.

In addition, we may transfer your Personal Information and other data to a third party in the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other assignment of all or part of our business, brands, affiliates, subsidiaries, or other assets.

We also rely on third party service providers to perform various services on our behalf, such as payment, networking, marketing, analysis, hosting, and data storage. Please find below a list of our third-party service providers that may process your Personal Information (with links to their privacy policy):

• AWS: We use AWS for hosting our web application. See their Usage and Privacy Policies.

• GoDaddy: We use GoDaddy for hosting our website. See their Hosting Agreement.

• MongoDB: We use MongoDB to build the platform's backend architecture and database. See their Privacy Policy.

• HubSpot: We use HubSpot to track sales. See their Privacy Policy.

• Mailchimp: We use Mailchimp to create and send our newsletter and forms. See their Privacy Policy.

If we provide your Personal Information to third-party service providers, we will take reasonable steps to ensure that the rules set out in this Policy are followed and that these third parties provide sufficient safeguards for the implementation of appropriate security measures. We also require that they use your Personal Information only for the purpose for which it was provided. When our service providers no longer require your Personal Information for these limited purposes, we ask them to destroy that information. In certain circumstances, we may allow our service providers to keep aggregated, anonymous, or statistical data that does not identify you. We do not allow third-party service providers to disclose your Personal Information to unauthorized third parties or to use it for their own marketing purposes. If you would like more information on our service providers, please contact us using the contact details in the "Contact Us" section below.

If we otherwise intend to disclose your Personal Information to a third party, we will identify that third party and the purpose of the disclosure, and obtain your consent.

CONSERVATION OF PERSONAL INFORMATION

We will only use, disclose, or retain your Personal Information for the time necessary to achieve the purposes for which the information was collected and to the extent permitted or required by law. If you would like more information about the periods during which your Personal Information will be kept, please contact us using the contact details in the "Contact Us" section below.

INFORMATION SECURITY

We have implemented physical, organizational, contractual, and technological security measures to protect your Personal Information and other data from loss or theft, unauthorized access, disclosure, copying, use, or modification. We have taken steps to ensure that only those employees who need to access your Personal Information in the performance of their duties have access to them.

Despite the measures described above, no method of transmission or storage of data is 100% secured or error-free. We can not, therefore, guarantee absolute security. If you have reason to believe that your interaction with us is no longer secure (for example, if you believe that the security of the data you have provided to us has been compromised), please contact us immediately using the contact details in the "Contact us" section below. If we become aware of a breach of our security systems involving your Personal Information, we will notify you and report it to the appropriate authorities in accordance with applicable laws.

UNSUBSCRIBE FROM COMMUNICATIONS

If you no longer wish to receive emails from us in connection with marketing, you may opt out of receiving such emails by clicking on the "unsubscribe" link located at the bottom of all emails you receive from us. You can also unsubscribe by contacting us directly using the contact details in the "Contact Us" section below.

We will endeavor to respond promptly to your request for unsubscription, but we kindly ask you to allow us a reasonable time to process your request. Please note that if you decide not to receive marketing-related emails, we may still need to send you communications regarding your use of our Services or Products, or other matters.

RIGHTS REGARDING YOUR PERSONAL INFORMATION

In certain circumstances and in accordance with the GDPR or other applicable privacy laws, a person has the following rights:

• Access: The right to ask if we process information and, if necessary, to request access to Personal Information. This allows the person to receive a copy of the Personal Information we hold and certain other information about them;

• Correction: The right to request the correction of any incomplete or inaccurate personal information that we hold;

• Deletion: The right to ask us to delete or remove Personal Information in certain circumstances. There are certain exceptions under which we may refuse a request for deletion, for example when Personal Information is required to comply with the law or claims;

• Restriction/limitation: The right to ask us to suspend the processing of certain Personal Information, for example to establish their accuracy or the reason for their treatment;

• Transfer: The right to request the transfer of certain Personal Information to a third party;

• Objection/Opposition: A person may dispute that we are processing Personal Information on the basis of a legitimate interest (or that of a third party) or for their own marketing purposes. However, we may be allowed to continue processing the data;

• Automated Decisions: The right to challenge any automated decision made when it has a legal effect or other similar significant effects and request that it be reconsidered;

• Consent: The right to withdraw consent when we process Personal Information with the consent of the individual.

You also have the right to file a complaint with a Privacy Control Authority (or Data Protection Authority), particularly in the country/state /province where you normally reside, where we are based, or where an alleged violation of the Personal Information Protection Act has occurred.

To exercise any of these rights, please contact us using the contact details in the "Contact Us" section below. Please note that we may require you to provide proof of identity to respond to your request. This identification data will only be used for this purpose.

INTERNATIONAL TRANSFER AND INFORMATION STORAGE

Your Personal Information is currently stored in Quebec (Canada). Where appropriate, it may be stored and processed in any country where we have facilities or in which we use third-party service providers. In the latter case, your Personal Information may be transferred to countries outside your country of residence, which may have different personal data protection rules than your country. If this data is outside your country, it is subject to the laws of the country in which it is located and may be disclosed to the governments, courts, or law enforcement or regulatory agencies of that other country, in accordance with the laws in force in that other country. However, our practices with respect to your Personal Information will at all times be governed by this Privacy Policy and, where applicable, we will comply with the requirements of the GDPR regarding the protection of the transfer of Personal Information from the EU/EEA to a third country.

WEBSITES AND THIRD-PARTY SERVICES

This Policy applies only to our Services and Products. This Policy does not extend to websites, products, or services provided by third parties. We do not assume any responsibility for the privacy practices of such third parties and we encourage you to review all third-party privacy policies before using third-party websites, products or services.

INFORMATION CONCERNING CHILDREN

We do not knowingly collect Personal Information concerning children under the age of 16. If you are under the age of 16, you must not provide us with your Personal Information. If you are a parent or guardian and you discover that your child under the age of 16 has provided Personal Information, you can notify us by using the contact details in the "Contact Us" section below and request that we delete this child's Personal Information from our systems.

UPDATES TO THE PRIVACY POLICY

This Policy is current as of the "last updated" date that appears at the top of this page. We may change this Policy from time to time. When changes are made to this Policy, they will become effective immediately upon publication in a revised version of the Policy and posted on our Website unless otherwise specified. We may also communicate changes through our Services or other means. By submitting your Personal Information to us, registering for or using any of the services offered, using our Website or engaging voluntarily with us after publication or communication of a notice of change to this Policy, you agree to that we collect, use, and disclose your Personal Information as set out in the Policy.

CONTACT US

Any comments, questions, concerns, requests, or complaints regarding your Personal Information or our privacy practices (including for service providers outside your country of residence) should be sent to our Privacy Officer, as follows:

By email: privacy@classo.org