PRIVACY NOTICE

This Privacy Notice was last updated on July 28th, 2023

This Privacy Notice  describes the personal information Numerade (“ Numerade ”,   “ we ”, “ our ”, or “ us ”) collects when you interact with us through our website or our mobile application (collectively, the “ Website ”), how we use this information, with whom we share it, and the choices you have in connection with this.

OUR ROLE IN DATA PROCESSING

The entity responsible for the collection and use (processing) of your personal information is Numerade. You can contact Numerade by telephone at 833-686-3723, by email at support@numerade.com  or mail at 680 E COLORADO BLVD, SUITE 180, PASADENA, CA 91101. Numerade is a controller under the UK General Data Protection Regulation and/or EU General Data Protection Regulation (collectively, “GDPR” or “EU data protection law”).

The Services are controlled and operated by us from the United States of America (“ U.S. ”). In accordance with U.S. laws, in certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in other countries may be entitled to access your personal data.

INFORMATION COLLECTION AND USE

We collect personal information, which is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, to you, when you engage with our Services and includes data protection as such term is defined under EU or UK data protection laws. Specifically, we collect personal information directly from you, automatically as you engage with our websites or mobile applications, and from third-party sources as described below.  

  1. Information Collected Directly From You

We collect personal information directly from you when you:

  • Make a purchase . If you make a purchase on our website, we will collect from you your identifiers  (name, email address, address) and your payment information  (debit card or credit card). We use this information to process your order, process your payment, provide you access to our services, and to communicate with you regarding your order. To the extent EU or UK data protection law applies, the legal basis for this is the performance of our contract with you. If you do not provide us with this information, we cannot provide you with our services. We share this information with our third-party payment processor.

As you engage with our Website, we use tracking technology to automatically collect the items you have viewed or put in your shopping cart but haven’t purchased. We will send you reminder emails of those items, if you have provided us your identifiers (email address) by subscribing to our newsletter or creating an account. We share this information with our marketing service provider. You can unsubscribe to these emails at any time by clicking the UNSUBSCRIBE button at the bottom of the email. Please note that we will continue to send you notifications necessary to the services or requested products or services. To the extent EU data protection law applies, the legal basis for this is your consent.

  • Create a Parent or Student Account.   When you create a parent or student  account to use our services, we will collect from you your identifiers  (name, email address, date of sign up, where applicable ), your account login information ( email  and we store your password in a hashed form), your order history (previous purchases or saved items). We use information to create and manage your account, update you on your order, send you marketing communications and promotions, and to communicate with you regarding our services. To the extent EU data protection law applies, the legal basis for this is the performance of our contract with you, if we do not process this information we cannot maintain your account.

  • Subscribe to marketing emails or newsletter.  If you subscribe to our marketing emails, we will collect from you, your identifiers  (email address) to fulfill your request to receive information we feel may be of interest to you and to send you promotional discounts. Our communications contain tracking technologies, provided by our marketing service provider, to gain insight into behavior of recipients. With the help of these technologies, we can analyze whether a predefined action took place by a recipient, such as opening our communications, in order to better adapt and distribute our communications. When you opt-in to our marketing communications, you are opting into the use of these technologies. You can unsubscribe to these emails at any time by clicking the UNSUBSCRIBE button at the bottom of the email. Please note that we will continue to send you notifications necessary to the Services or requested products or services. To the extent EU data protection law applies, the legal basis for this is your consent.

  • Contact us.  When you contact us through either our live-chat feature, email, or our customer service line, we may collect from you your  identifiers (name, email address, address), your account information (order number), your purchase information  (items in your order), and your financial information  (credit card or debit card). We use this information to respond to your inquiries, process returns or refunds, and communicate with you. We share this information with our customer service provider who operates our live-chat feature and customer service line. To the extent EU data protection law applies, the legal basis for this is performance of a contract with you. If you do not provide us with this information, we will not be able to communicate with you.

  • Interact with us on social media . When you interact with us through social networking websites, like Instagram, Facebook, or Twitter (each or collectively “ Fan Page(s) ”) we collect basic engagement metrics (likes, reposting, or sharing on your feed) and use it to tailor content and marketing and use it to improve user experience as set forth in each section. Engagement metrics are collected at a campaign or audience level and do not identify or relate to a specific individual or account. Please note that when you post personal information to our social networking websites, it will be viewable by other users of these websites, and we cannot prevent further use of the personal information by third parties. For more information, please see . Facebook’s Privacy Policy , Twitter’s Privacy Policy , and Instagram’s Privacy Policy .

Facebook, Twitter, and Instagram (the “ Social Networks ”) process personal information in the USA where the laws may be less protective than in your country of residence. For example, in accordance with U.S. laws, in certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in other countries may be entitled to access your personal data.

  • Fan Pages . When interacting with our Fan Pages, we collect, from you, your personal identifiers  (first and last name) and visual information  (photograph (i.e. profile picture)), as well as any information that you provide when interacting with our Fan Pages (e.g., commenting, sharing, and rating). We use this information to advertise our products, for events and invitations, and to communicate with users via the contribution and comment function.

To the extent the EU or UK data protection laws apply, the legal basis for the processing is our legitimate interest in advertising our products via our Fan Pages and communicating with users, customers, and interested parties.

Because our Fan Pages are publicly accessible, when you use them to interact with other users, for example by posting, leaving comments or liking or sharing posts, any personal information that you post in them or provide when registering can be viewed by others or used by them as they see fit.

  • Facebook Page Insights . When you visit our Facebook Fan Page, Facebook records your IP address and other information about your usage behavior on our Facebook Fan Page. Facebook collects, through trackers in the browser of your device or via the advertising ID (IDFA from Apple or GAID from Google), when you open the Facebook app through your mobile device (e.g. smartphone or tablet). Facebook uses this information to provide us with statistical evaluations of the use of our Facebook Fan Page. We receive this information directly from Facebook, in the form of aggregated data and anonymous statistics regarding certain data points, such as: age; gender; city/country; device; inquiries from fans about other Facebook fan pages; region and language settings of the users; proportion of men and women; the number of people reached; clicks on posts, "Likes” and reactions; comments and shared content; and total video views. We use this information to analyze and improve the advertising campaigns we conduct through our Facebook Fan Page. We do not collect or process any other personal information in connection with Facebook’s “Page Insights” function.

For the purpose of the EU and UK data protection laws apply, we are joint controllers with Facebook for this processing. To the extent the EU or UK data protection laws apply, the legal basis for this processing is our legitimate interest in statistical evaluation of users on our Facebook Fan Page for the improvement and adjustment of our advertising measures based on the information collected. If you object to this processing of your personal information and believe you have an overriding interest, you can submit your objection via email to support@numerade.com .

We do not retain this information independently. For information on data protection and the storage period on Facebook in relation to its "Page Insights" function, see here  and Facebook’s Privacy Policy . It has been contractually agreed with Facebook that Facebook is responsible for providing you with information about the processing for Page Insights.

  • Information Processed Solely by Facebook . We do not know how Facebook uses personal information for its own purposes, how long the personal information is stored on Facebook or whether Facebook data is passed on to third parties.

If you are currently logged in to Facebook as a user, Facebook automatically collects, through trackers on your device, your Facebook ID or a link between the Facebook ID and the advertising ID (IDFA from Apple or GAID from Google) when you open the Facebook app through your mobile device (e.g. smartphone or tablet). This enables Facebook to understand that you have visited our Facebook Fan Page along with other Facebook pages that you have clicked on, whether you clicked on Facebook buttons integrated into websites that partner with Facebook, and other online interactions that report user data to Facebook. Based on this data, content or advertising tailored to you can be offered.

  • For benchmarking . Numerade may deidentify or aggregate your personal information for benchmarking purposes. To the extent EU/UK data protection law applies, the legal basis for this processing is our legitimate interest in the improvement of our business and Services.  Once information is deidentified or aggregated, Numerade may share this information with third parties or use it for marketing purposes

Numerade may also use the personal information collected for the above purposes to comply with the law and for other limited circumstances as described in HOW WE SHARE YOUR PERSONAL INFORMATION.  

  1. Information Collected Automatically

In addition to the personal information you provide, we also collect information automatically via cookies as you use the Services. This information includes the following internet and other electronic network activity information .

We use usage, device, and location information to: (i) track you within the Services; (ii) enhance user experience; (iii) conduct analytics to improve the Services; (iv) prevent fraudulent use of the Services; and (v) diagnosis and repair Services errors, and, in cases of abuse, track and mitigate the abuse.

Particular cookies to note on the Services include:

  • Google Analytics.  We use Google Analytics to collect information on your use of the Website to improve our Website. In order to collect this information, Google Analytics may set cookies on your browser, or read cookies that are already there. Google Analytics may also receive information about you from applications you have downloaded that partner with Google. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to our Websites or to another application which partners with Google is restricted by the Google Analytics Terms of Use and the Google Privacy Policy available here . To prevent your data from being used by Google Analytics, you can download the Google Analytics opt-out browser add-on for Google Analytics which can be found here . This may be a sale under CPRA. To opt out of this cookie, follow the instructions in the YOUR INFORMATION CHOICES  section of the Privacy Policy or visit Do Not Sell My Personal Information https://www.onetrust.com/products/cookie-consent/.
  • Microsoft Clarity  Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement

In general, to disable cookies and limit the collection and use of information through them, you can set your browser to refuse cookies or indicate when a cookie is being sent. When you opt-out an opt-out cookie will be placed on your device. The opt-out cookie is browser and device specific and will only last until cookies are cleared from your browser or device.

HOW WE SHARE YOUR PERSONAL INFORMATION

Numerade shares the personal information identified in this Privacy Notice in the following instances:

  • Within Numerade.  Where necessary, we share your personal information within Numerade for legitimate business purposes in order to efficiently carry out our business and to the extent permitted by law. To the extent EU data protection law applies, the legal basis for this is our legitimate interest in carrying out our business operations efficiently.

  • With service providers.  We share your personal information with our service providers that assist us in providing the services, such as our e-commerce provider, payment processor, IT support, marketing provider, communications provider, cloud and hosting provider, email provider, and shipping and fulfillment provider.

  • With Advertising Providers.   For advertising purposes, we may share your personal identifiers  (hashed email address), commercial information  (price point of items purchased) and demographic information  (e.g., gender, age) about you to generate a “lookalike audience” of prospective   consumers of our Services through the Facebook, Google or other advertising platforms. This allows us to target advertisements on their network to potential consumers who appear to have shared interests or similar demographics to our existing consumers.

  • With Third Parties.   We may need to disclose your personal information to third parties, such as legal advisors, law enforcement agencies, or governmental/regulatory bodies in order to protect our legal interests and other rights, protect against fraud or other illegal activities, prevent harm, for risk management purposes, and to comply with our legal obligations.

  • In the event of a corporate reorganization.  In the event that we enter into, or intend to enter into, a transaction that alters the structure of our organization, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our assets, we would share your personal information with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction. We will also share your personal information with third parties if we undergo bankruptcy or liquidation, in the course of such proceedings. To the extent EU data protection law applies, the legal basis for this is our legitimate interest in carrying out our business operations.

  • For legal purposes .  We will share your personal information where we are legally required to do so, such as in response to tax obligations, court orders, law enforcement or legal process, including for national security purposes; to establish, protect, or exercise our legal rights, as required to enforce our terms of use or other contracts; to defend against legal claims or demands; to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person; or to comply with the requirements of any applicable law. To the extent EU data protection law applies, the legal basis for this is compliance with legal obligations.

  • With your consent.  Apart from the reasons identified above, we may request your permission to share your personal information for a specific purpose. We will notify you and request consent before you provide the personal information or before the personal information you have already provided is shared for such purpose. You may revoke your consent at any time.

Sharing in the Last Twelve (12) Months

For a Business Purpose.  In the preceding twelve (12) months, Numerade has disclosed the following categories of personal information for a business purpose to the following categories of third parties:

  • We have disclosed your personal identifiers, internet and other network activity information, financial information and customer records information to service providers that perform services on our behalf. These providers include our e-commerce provider, payment processor, IT support, marketing provider, communications provider, cloud and hosting provider, and email provider.

  • We have disclosed your internet or other electronic network information to our IT support to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to identify and repair website errors that impair functionality.

  • We have disclosed your internet or other electronic network information and location information to our IT support and data analytics provider to maintain, improve, and upgrade Numerade services.

YOUR RIGHTS AS A NEVADA RESIDENT

If you are a consumer in the State of Nevada, you may request to opt-out of the current or future sale of your personal information. We do not currently sell any of your personal information under Nevada law, nor do we plan to do so in the future. However, you can submit a request to opt-out of future sales by contacting us at support@numerade.com. Please include “Opt-Out Request Under Nevada Law” in the subject line of your message.

 

YOUR RIGHTS AS AN INDIVIDUAL OF CANADA

Individuals in Canada are entitled to certain rights under PIPEDA. If our processing of your personal information is subject to PIPEDA, you may be entitled to the following rights:

  • Right to lodge a complaint : You have the right to lodge a complaint directly to us regarding our alleged noncompliance with PIPEDA. We will review and respond to your complaint. PIPEDA-related complaints can be directed to support@numerade.com .
  • Right to access:  You have the right to ask us for copies of your personal information. This right has some exemptions, which means you may not always receive all the personal information we process. Applicable exemptions may include the management information exemption (data that we process for management forecasting or management planning about a business or other activity), confidential references (references given or received about an individual), or certain instances of ongoing or prior negotiations with the requestor, among others.  

  • Right to rectification:  You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

  • Right to erasure:  You have the right to request erasure of your personal information that we are not obligated to keep in some cases (also known as the right to be forgotten).  For example, you can request us to delete such personal data if:  (i) we no longer need the data for the purpose it was collected for, (ii) we process the data based on your consent and you revoke your consent, (iii) you object to our processing based on legitimate interest (and we do not have an overriding legitimate interest), or (iv) you object to our processing the personal data for direct marketing purposes.  We may not be able to immediately erase your personal information if we have a lawful reason or a legal or contractual obligation to retain the information or continue the processing.  

  • Right to restrict processing:   If you believe that your personal data is inaccurate, that our processing is unlawful, or that we do not need the information for a specific purpose, you have the right to request that we restrict the processing of such personal data. You also have the possibility to request that we stop processing your personal data while we assess your request. If you object to our processing (per your right to object below), you may also request us to restrict processing of that personal data while we make our assessment.

  • Right to object to processing:  You have the right to object to processing of your personal data which is based on our legitimate interest (Article 6(1)(f) UK GDPR), by referencing your personal circumstances. You also have the right to object to our use of your personal data for direct marketing purposes. When you object to our use of your data for direct marketing purposes ( i.e.  let us know that you no longer wish to receive direct marketing from us), we will stop sending you direct marketing correspondence.

  • Right to data portability:  This right only applies to personal information you have given us. You have the right to ask that we transfer the personal information you gave us from one organization to another or give it to you.

  • Automated Processing: You have the right to not be subjected to solely automated processing of your data in a way which will have a material impact on you.

  • Rights under Quebec 64:   If you are a resident of Quebec, you have some additional rights as described below:

  • Decisions based on automated processing. If we use your personal information to render decisions based exclusively on automated processing, you have the right to be informed of this at or before the time of the decision.
  • De-indexation and cessation of dissemination.  Under certain circumstances, you have the right to request we cease disseminating personal information or de-index any hyperlink that provides access to this information by a technological means. You have this right when dissemination would violate the law, violate a court order, or cause serious injury to your privacy or reputation.
  • Right to request source of information.  Where we collect your personal information from another person or entity (i.e. not you), you may request us to inform you of the source of the data.

YOUR RIGHTS AS AN INDIVIDUAL IN THE EUROPEAN UNION

Individuals in the European Union are entitled to certain rights under the General Data Protection Regulation (GDPR). If our processing of your personal information is subject to the GDPR, you may be entitled to the following rights:

  • Right to access:  You have the right to ask us for copies of your personal information. This right has some exemptions, which means you may not always receive all the personal information we process. Applicable exemptions may include the management information exemption (data that we process for management forecasting or management planning about a business or other activity), confidential references (references given or received about an individual), or certain instances of ongoing or prior negotiations with the requestor, among others.  

  • Right to rectification:  You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

  • Right to erasure:  You have the right to request erasure of your personal information that we are not obligated to keep in some cases (also known as the right to be forgotten).  For example, you can request us to delete such personal data if:  (i) we no longer need the data for the purpose it was collected for, (ii) we process the data based on your consent and you revoke your consent, (iii) you object to our processing based on legitimate interest (and we do not have an overriding legitimate interest), or (iv) you object to our processing the personal data for direct marketing purposes.  We may not be able to immediately erase your personal information if we have a lawful reason or a legal or contractual obligation to retain the information or continue the processing.  

  • Right to restrict processing:   If you believe that your personal data is inaccurate, that our processing is unlawful, or that we do not need the information for a specific purpose, you have the right to request that we restrict the processing of such personal data. You also have the possibility to request that we stop processing your personal data while we assess your request. If you object to our processing (per your right to object below), you may also request us to restrict processing of that personal data while we make our assessment.

  • Right to object to processing:  You have the right to object to processing of your personal data which is based on our legitimate interest (Article 6(1)(f) UK GDPR), by referencing your personal circumstances. You also have the right to object to our use of your personal data for direct marketing purposes. When you object to our use of your data for direct marketing purposes ( i.e.  let us know that you no longer wish to receive direct marketing from us), we will stop sending you direct marketing correspondence.

  • Right to data portability:  This right only applies to personal information you have given us. You have the right to ask that we transfer the personal information you gave us from one organization to another or give it to you.

  • Right to lodge a complaint:   You have the right to lodge a complaint with the relevant Supervisory Authority. A list of Supervisory Authorities is available  here .  

To exercise these rights, please contact us at  support@numerade.com .        

YOUR INFORMATION CHOICES

  • Correct or view your personal information:   You may access your Numerade account profile to correct or view certain personal information of yours in our possession and which is associated with your profile.  

  • Marketing emails:  You may opt-out of receiving marketing emails from us by clicking the “unsubscribe” link provided with each email. Please note that we will continue to send you emails necessary to the Services or any assistance you request.

  • Marketing text messages:  You may opt-out of receiving marketing text messages from us by responding “STOP” to any of our text messages.

  • Push notifications:   If you have enabled push notifications, you may disable these at any time by updating your device settings.

  • Opt Out of Other Cookies:  All session cookies are temporary and expire after you close your web browser. Persistent cookies can be removed by following your web browser’s directions. To find out how to see what cookies have been set on your computer or device, and how to reject and delete the cookies, please visit:  https://www.aboutcookies.org/ . Please note that each web browser is different. For information on reviewing or deleting cookies from specific browsers, click on the appropriate browser: Firefox , Firefox IOS , Firefox Android , Safari , Safari Mobile , Chrome , Internet Explorer , Microsoft Edge , Opera . To find information relating to other browsers, visit the browser developer’s Website and mobile application. If you reset your web browser to refuse all cookies or to indicate when a cookie is being sent, some features of our website and mobile application may not function properly. If you choose to opt out, we will place an "opt-out cookie" on your computer. The "opt-out cookie" is browser specific and device specific and only lasts until cookies are cleared from your browser or device. The opt-out cookie will not work for essential cookies. If the cookie is removed or deleted, if you upgrade your browser or if you visit us from a different computer, you will need to return and update your preferences.

  • Opt out of Interest Based Advertising :  To opt out of internet based advertising generally or learn more about the use of this information, you can visit the Network Advertising Initiative  (NAI) or the Digital Advertising Alliance  (DAA). The DAA offers consumers a WebChoices  tool to opt out of interest-based advertising and other applicable uses of Web-viewing data by DAA's participating companies.  The NAI offers a similar opt-out service for NAI members.  Visit NAI’s Consumer Opt Out  web page to learn about NAI members who deliver tailored ads and opt-out of receiving them.   When you opt-out an opt-out cookie will be placed on your device. The opt-out cookie is browser and device specific and will only last until cookies are cleared from your browser or device.   You may also disable cookies and limit the collection and use of information through them by setting your browser to refuse cookies or indicate when a cookie is being sent.  If you are a resident of the European Union (EU) or the European Economic Area (EEA), you can also visit the European Interactive Digital Advertising Alliance’s (EDAA) opt out web page  to opt out of interest based advertising or learn more about your information choices.  

DO NOT TRACK

We do not support Do Not Track (DNT).   Do Not Track is a preference you can set to inform websites and applications that you do not want to be tracked.

DATA USAGE FOR AI

Any personal data provided by you or collected during your interaction with our services is not shared with, transferred to, or used for training any Artificial Intelligence (AI) models.

GOOGLE API SERVICES DISCLOSURE

Numerade's use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy , including the Limited Use requirements.

INFORMATION SECURITY

We implement and maintain reasonable security measures, such as access controls and encryption, to protect the personal information we collect and maintain. However, no security measure or modality of data transmission over the Internet is 100% secure and we are unable to guarantee the absolute security of the information we have collected from you.

AGE RESTRICTION

The Services are not intended for individuals under the age of sixteen (16). If we learn that we have collected or received personal information from a child under the age of sixteen (16), we will delete that information. If you believe we might have information from or about a child under the age of sixteen (16), please contact us at support@numerade.com.

DATA DELETION

If you wish to delete your data, please follow these steps: To delete your account, proceed to your "Account" page and click on the "Delete Account" link located at the bottom of the page. This action will permanently remove all your personal information from our system. Please note that this process is irreversible and once completed, your data cannot be recovered. By deleting your account, you acknowledge and agree that all personal data associated with your account will be permanently deleted in accordance with our data retention policies and applicable laws and regulations.

CHANGES TO THIS PRIVACY NOTICE

We may change this Privacy Notice from time to time. We will post the changes to this page and will indicate the date the changes go into effect. We encourage you to review our Privacy Notice to stay informed. If we make changes that materially affect your privacy rights, we will notify you with a prominent post on our Services and obtain your consent, if required.

CONTACT

For any questions, comments, or complaints about our Privacy Policy or practices, please contact us at:

support@numerade.com