Date of last revision of this Policy: February 3rd, 2023
1.0 What Does This Policy Apply To?
“Personal Information” is any information provided to us or generated within the Public Website that may directly or indirectly identify an individual, such as name or email address, or other information which could be reasonably linked to such identifying information. Unless otherwise specified, Personal Information referenced in this Policy is interchangeable with Personally Identifiable Information, which is information that, that when used alone or in combination with other information, can identify an individual. Personal Information does not include de-identified information (i.e., information that does not identify you) such as usage data.
Our public Website contains links to other websites and services that we do not own or operate. By clicking on those links, you will leave our Public Website. Those third-party websites and services are governed by separate and independent privacy policies, which we recommend you read carefully.
2.0 How Do We Collect Your Personal Information?
Personal Information You Voluntarily Provide To Us
You may voluntarily provide us with Personal Information, such as your name, email address, phone number and company name, when you subscribe to our mailing list, fill in a sales lead form, make an inquiry or respond to an offer on our Public Website.
We do not seek or collect sensitive data from prospective customers, only basic contact information data such as name, email address and phone number.
Based on applicable law, filling in a form on our website is your implied consent. We also rely on opt-in consent when applicable law requires us to obtain explicit consent or when you proactively opt to receive marketing communication.
Information We Automatically Collect
We do not collect geolocation data.
3.0 How Do We Use Your Information?
To Respond To Your Communications
We respond to inquiries, comments, feedback or questions when prospects fill out online forms on our Public Website. We may also use your contact information to send you notices about changes to our terms, conditions and policies.
To Engage In Marketing Or Promotional Activities
If the information you share identifies you as a K-12 school district or other likely educational institution decision maker or influencer for which the Edsby service would be commercially suitable, and your interactions with our marketing materials suggest interest in Edsby, you may receive individualized outreach from us, such as a telephone call or personalized email from a sales representative.
Other non-targeted Public Website respondents who have filled in a form or chatted with a chatbot may receive periodic newsletter-style or other emails from Edsby.
Our marketing emails always include an “unsubscribe” link so that you can opt out of receiving marketing emails from Edsby. You can also email us at [email protected] to opt out of receiving promotional emails. We will obtain your consent before sending you marketing communications if required to do so by applicable laws.
Note that we do not track visitors of our Public Website outside of our website.
To Develop And Improve Our Public Website
We collect usage information about how visitors enter and navigate our Public Website that helps inform optimizations to its marketing content. We collect this information through cookies and other similar technologies. See Section 9.0 for more information and details on how to disable cookies.
4.0 To Whom Do We Disclose/Transfer Your Personal Information?
We do not sell your Personal Information or the content you provide to us. We do not rent or otherwise share any Personal Information for commercial purposes, even in an aggregated or de-identified form. We do not combine Personal Information with data from other sources to attempt to build a database product. Personal Information collected from prospects on our Public Website is for our sole use.
We limit who we share your Personal Information with. We also limit what information we share and how third parties may use, access, process or store such information in the course of performing duties for us.
The full list of third-party services used by our Public Website for collecting or managing Personal Information are:
- Bablic, which manages translated versions of our Public Website
- FlowXO, which provides an automated support chatbot on our Public Website for student and parent users of our product seeking login or other basic help
There are only very limited circumstances in which we may disclose or share your Personal Information with third parties other than these. Those circumstances include:
- To subsidiaries or affiliated companies in the event of a merger or acquisition, or a due diligence process as part of a transaction; and
- If required to comply with relevant laws or respond to subpoenas or warrants served on us or to protect/defend our company’s rights, clients, or Public Website visitors
If we need to disclose your Personal Information for any other purpose, other than those listed above, we will first seek your consent to do so.
5.0 How Do We Protect Your Information?
We are committed to protecting your Personal Information. Edsby employs a variety of physical, administrative, and technical safeguards designed to protect Public Website visitors’ Personal Information against loss, misuse and unauthorized access or disclosure. We also restrict access to Personal Information to Edsby staff who need to know that information for the purpose set out in this Policy and ensuring those staff acknowledge confidentiality. We retain Personal Information only for as long as is necessary for the purposes for which it was collected, in accordance with contractual terms, or as is permitted or required under applicable laws.
6.0 What Are Your Choices?
It is your choice whether you provide us with your Personal Information on our Public Website, by filling in a contact sales or other form. However, if you choose not to provide information that is required to process your requests or use features of our Public Website, we may be unable to process your requests, or you may be unable to use those features that require the information to function.
You have rights and choices as it relates to your Personal Information. Those include:
- The right to access and/or correct your Personal Information, which we collected on our Public Website. You may access, update or correct your Personal Information and exercise your rights by emailing us at [email protected] or using the contact information below. We will consider and respond to all requests per applicable laws.
- The right to opt out of marketing communication from us either by clicking on the “unsubscribe” link at the bottom of all promotional or sales emails or by contacting us.
- The right to withdraw your consent for us to use your Personal Information. Withdrawing your consent will not affect the lawfulness of any processing we conducted before your withdrawal or the processing of your Personal Information for any other lawful grounds other than consent.
- You may disable cookies at any time to prevent information collection and tracking. Please see Section 9.0 for more information.
When we receive a request from you to exercise your right, we will verify your identity by matching the identifying information you provide to us with the Personal Information we have about you.
7.0 Children’s Privacy
Our Public Website is not intended for use by children under 13 years of age. We do not knowingly collect information on our Public Website from children (as defined in your jurisdiction). If you are a parent or guardian who believes that we have inadvertently collected Personal Information from your child without proper consent, please contact us at [email protected] and we will immediately investigate and delete any such information.
8.0 Do We Transfer Your Information Internationally?
Data collected from Public Website visitors and their interactions with our website and marketing assets is stored in Edsby’s CRM, HubSpot, hosted in the United States. From time to time, we may need to transfer your Personal Information to Canada, our headquarters, or another country where Edsby or authorized third parties operate. These countries may not necessarily have data protection laws as comprehensive or protective as those in your country of residence; however, when we transfer your Personal Information in this manner across country borders, we implement adequate measures for its protection and for compliance with applicable laws.
9.0 Cookies and Similar Technologies
What information do we collect using cookies?
The cookies we collect primarily collect information so as to gauge a prospect’s interest in licensing Edsby for their Education Organization. They also remember visitor preferences, such as language preferences, so that the user can have a better experience.
Some cookies on our Public Website are set by us (i.e., first-party cookies) and some cookies are set by third parties (i.e., third-party cookies). To learn more about cookies, visit www.allaboutcookies.org.
How can you manage cookies?
Although most browsers accept cookies, you can set your browser to reject cookies. You will need to follow the instructions contained in your browser’s help file (usually located within the “Help,” “Tools,” or “Edit” settings). If you have more than one browser, the opt-out or settings you set will only apply to that specific browser and not the others. If you choose to disable cookies, some of the features and services on our Public Website might not function properly.
11.0 How To Contact Us?
You may contact us at [email protected] with any questions or concerns you have related to your Personal Information. We may also be reached as follows:
68B Leek Crescent, Suite 200
Richmond Hill, Ontario
+1 (877) 337-0070
12.0 California Privacy Notice Addendum (“Addendum”)
If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA).
We may make changes to the Addendum. Please refer to the Addendum from time to time to keep yourself informed of how we may collect, use and disclose your Personal Information.
“Personal Information” means information that identifies, relates to, or could reasonably be linked directly or indirectly with a particular California resident. Personal Information does not include publicly available information from government records or de-identified or aggregated consumer information.
12.1 Categories of Personal Information
Over the past 12 months, we have collected the following categories of Personal Information for business purposes:
|A. Identifiers||Contact details, such as real name, alias, postal address, telephone or mobile contact number, Internet Protocol address, email address, and account name|
|F. Internet or other similar network activity||Interactions with our website, marketing emails, and advertisements|
|I. Professional or employment-related information||Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us|
|K. Inferences drawn from other personal information||Inferences drawn from any of the collected Personal Information listed above to augment our understanding of your preferences and characteristics|
12.2 Sources of Personal Information
We collect the categories of Personal Information in the following ways:
- Directly from you when: you contact us about an inquiry; and when you submit a form on our Public Website with your Personal Information or identify yourself to our chatbot
12.3 Disclosure of Personal Information for a Business Purpose
In the past 12 month, we disclosed the following categories of Personal Information for a business purpose:
|Category||Personal Information Disclosed To a Third Party For a Business Purpose|
|F. Internet or other similar network activity||Yes|
|I. Professional or employment-related information||Yes|
|K. Inferences drawn from other personal information||Yes|
We disclosed these categories of Personal Information to the following categories of third parties: Our CRM, our Public Website translation provider, our chatbot service provider, and legal authorities as required by law.
Please refer to 4.0 To Whom Do We Disclose/Transfer Your Personal Information?
12.4 Use of Personal Information
For more information about how we use your Personal Information, please see 3.0 How Do We Use Your Information?
12.5 Sale of Personal Information
Edsby does not sell your Personal Information for money to anyone. However, the definition of “sale” under the CCPA is very broad and it includes sharing information for analytics purposes. You can opt out of this either by contacting us at [email protected]
12.6 What are your Rights
As a California resident, you have the following rights, subject to certain exceptions and limitations:
Right to know, over the past 12 months, the categories and specific Personal Information we collect, use, disclose, and sell about you, the categories of sources from which we collected your Personal Information, our purposes for collecting or selling your Personal Information, the categories of your Personal Information that we have either sold or disclosed for a business purpose, and the categories of third parties with which we have shared Personal Information.
- Right to access and portability of Personal Information that we collected over the past 12 months. You also have the right to request we provide you with a copy of the Personal Information we collected in a portable, readily reusable format that allows you to transmit the information to a third party.
- Right to delete the Personal Information we have collected from you or maintain about you.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to [email protected].
We will not discriminate against you for exercising your CCPA rights.