Privacy Policy

Privacy Policy

BetterLesson Platform Privacy Notice

Last Updated: August 24, 2018

Welcome to BetterLesson, a content management and collaboration platform consisting of websites, services, software applications and networks that allows for the authorized download and distribution of written digital content over the internet (the “BetterLesson Platform”). The BetterLesson Platform is owned and operated by BetterLesson, Inc.

BetterLesson values the privacy of the users, subscribers, publishers, members, and others who visit and use the BetterLesson Platform (collectively or individually, “you”, “’You” or “Users”).

By using the BetterLesson Platform, you expressly consent to the information handling practices described in this notice. This Privacy Notice is incorporated into and is subject to the BetterLesson Platform Terms of Use. Your use of the BetterLesson Platform and any personal information you provide through the BetterLesson Platform are subject at all time to this Privacy Notice and the Terms of Use.

TABLE OF CONTENTS

  1. The Information BetterLesson Collects
  2. The Way BetterLesson Uses Information
  3. When BetterLesson Discloses Information
  4. Your Choices
  5. Data Security
  6. Children’s Privacy
  7. International Visitors
  8. In the Event of Merger or Sale
  9. Changes and Updates to this Privacy Notice
  10. Effective Date, Date Last Modified
  11. BetterLesson Contact Information

EU-U.S. and Swiss-U.S. Privacy Shield Frameworks

BetterLesson complies with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks as set forth by the United States Department of Commerce regarding the collection, use, and retention of personally identifiable information transferred from the European Union and Switzerland to the United States. Consistent with our commitment to protect personally identifiable information about individuals in the European Union, BetterLesson has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of Notice, Choice, and Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability (the “Privacy Shield Principles” or the “Principles”). BetterLesson’s EU-U.S. and Swiss-U.S. Privacy Shield Certification also extends to personally identifiable information that we receive directly through the Sites. More information on the EU-U.S. and Swiss-U.S. Privacy Shield and BetterLesson’s scope of participation in the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks are available at http://www.privacyshield.gov/welcome.

If there is any conflict between the terms in this privacy policy (“Privacy Policy”) and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

The Information BetterLesson Collects:

  • User-provided Information: You may provide to BetterLesson what is generally called ‘personally identifiable’ information (such as your name, email address, postal mailing address, home/mobile telephone number) if you log in to the BetterLesson Platform, or otherwise use the features and functionality of the BetterLesson Platform.
  • ‘Cookies’ Information: When you access the BetterLesson Platform, we may send one or more cookies & small text files containing a string of alphanumeric characters to your computer. BetterLesson may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the BetterLesson Platform. Persistent cookies can be removed. Please review your web browser ‘Help’ file to learn the proper way to modify your cookie settings. BetterLesson does not respond to “Do Not Track” signals.
  • ‘Automatically Collected’ Information: When you access the BetterLesson Platform or open one of our HTML emails, we may automatically record certain information from your system by using different types of tracking technology. This ‘automatically collected’ information may include Internet Protocol address (‘IP Address’), a unique device or user ID, version of software installed, system type, the content and pages that you access on the BetterLesson Platform, and the dates and times that you visit the BetterLesson Platform.

The Way BetterLesson Uses Information:

  • BetterLesson uses the information that you provide or that we collect to operate, maintain, enhance, and provide all of the features and services found on the BetterLesson Platform as well as to track user-generated content and Users to the extent necessary to comply as a service provider with the Digital Millennium Copyright Act.
  • We will use your email address, without further consent, for administrative communications such as notifying you of major BetterLesson Platform updates, for customer service purposes, to address copyright infringement or defamation issues, or to contact you regarding any content that you have posted to or downloaded from the BetterLesson Platform.
  • BetterLesson uses all of the information that we collect to understand the usage trends and preferences of our Users, to improve the way the BetterLesson Platform works and looks, and to create new features and functionality.
  • BetterLesson may use ‘Automatically Collected’ information and ‘Cookies’ information to: (a) automatically update the BetterLesson application on your system; (b) remember your information so that you will not have to re-enter it during your visit or the next time you access the BetterLesson Platform; (c) monitor aggregate site usage metrics such as total number of visitors and pages accessed; (d) provide such metrics to Users as they pertain to such User’s uploaded content; and (e) track your entries, submissions, and status in any promotions or other activities.

When BetterLesson Discloses Information:

  • BetterLesson does not share your personally identifiable information with other organizations for their marketing or promotional uses without your prior express consent, provided however that, BetterLesson may share your personally identifiable information with (i) third-party entities or organizations for data analysis and BetterLesson may share, or authorize such third party entities or organizations to share, the results of such analysis with valued partners under obligations of confidentiality, and (ii) a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of BetterLesson, Inc.’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by BetterLesson, Inc. about our Users is among the assets transferred. Please be aware, that any personally identifiable information that you voluntarily choose to display on the BetterLesson Platform such as when you publish attribution credits for documents or profile information becomes publicly available and may be collected and used by others without restriction.
  • We may disclose User information to affiliated companies or other businesses or persons to provide web site hosting, maintenance, and security services; fulfill orders; conduct data analysis and create reports; and, offer certain functionality and assist BetterLesson in improving the BetterLesson Platform and creating new services features. We require that these parties process such information in compliance with this Privacy Notice, we authorize only a limited use of such information, and we require these parties to use reasonable confidentiality measures.
  • BetterLesson may disclose User information if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws (such as U.S. Copyright law) or respond to a court order, judicial or other government subpoena, or warrant in the manner required by the requesting entity.
  • BetterLesson also reserves the right to disclose User information that we believe, in good [faith, is appropriate or necessary: to take precautions against liability; to protect BetterLesson from fraudulent, abusive, or unlawful uses; to investigate and defend ourselves against third-party claims or allegations; to assist government enforcement agencies; to protect the security or integrity of the BetterLesson Platform; or to protect the rights, property, or personal safety of BetterLesson, our Users, or others.
  • BetterLesson shows aggregate geographical information about visitors on BetterLesson document pages in our analytics section. This information includes the cities and countries of people viewing documents, the document which was viewed, and the time the document was viewed. This information is publicly available to all BetterLesson users. If you do not want this geographical information recorded and displayed in this way, you can prevent BetterLesson from doing so by following these steps. First, create a BetterLesson account. Then, in account settings, select “Hide all geographical information.”

Details of data processing

BetterLesson processes your personal data as a customer and other customer’s personal data (in the following just “customer”) to provide the contractually agreed services.

Subject matter: The subject matter of the data processing is the performance of the services agreed between BetterLesson and customer by BetterLesson involving personal data provided by customer.

Duration: As between customer and BetterLesson, the duration of the data processing is determined by customer and its contractual commitments about the use of BetterLesson’s services.

Purpose: The purpose of the data processing by BetterLesson is the provision of the services initiated by the customer from time to time.

Nature of the processing: Cloud computing as platform and software as a service and such other services as described in the Documentation and initiated by the customer from time to time.

Type of personal data:

The type and extent of personal data that is subjected to BetterLesson’s data processing is determined and controlled by our customer as data controller in its sole discretion – this may include, but is not limited to the following:

  • First and last name
  • Title, work department, and manager/supervisor name
  • Employer
  • Contact information (company, personal and work email, phone, home address, physical business address, emergency contact details)
  • Photographs and videos
  • Biographical and directory information, including linked social media profile or posts
  • Company user names or IDs and login credentials
  • Identifiers related to work or personal devices used to access data exporter’s IT systems
  • Log information generated using data exporter’s IT systems
  • Actions performed by the employee while accessing or using the services
  • Training undertaken and training needs
  • Localization data

Categories of data subjects: Customer’s representatives and end-users including employees, contractors, collaborators and advisors of our customer (who are natural persons). 

Choice/Opt-Out

You may, of course, decline to share your personally-identifiable information with BetterLesson, in which case BetterLesson will not be able to provide to you some of the features and functionality found on the BetterLesson Platform. We provide you the opportunity to ‘opt-out’ of having your personally identifiable information used for certain purposes, and you may update, correct, or delete your user information and preferences at any time by following the directions here. BetterLesson will also delete the personally identifiable information that you have provided to us: (a) upon your request, or (b) upon termination of your BetterLesson account; provided, however, BetterLesson will retain a copy in its files of all personally identifiable information, if required for legal reasons.

You will be notified prior to when your personally identifiable information is collected by any third party that is not our agent/service provider, so you can make an informed choice as to whether to share your information with that party.

Please note that if you opt out of receiving our promotional or marketing emails, you may still receive certain service-related communications from us, such as administrative and services announcements and messages about your account.

If you are an EU or Swiss person about whom we hold personally identifiable information on a customer’s behalf, you may request access to, and the opportunity to update, correct or delete, such personally identifiable information. To submit such requests or raise any other questions, please contact the business that provided your personally identifiable information. You can also contact us and we will then contact that business. We reserve the right to take appropriate steps to authenticate an applicant’s identity, to charge an adequate fee before providing access and to deny requests, except as required by the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks.

To protect your privacy and security, we take reasonable steps to verify your identity before granting your account access or making corrections to your information. You are responsible for maintaining the secrecy of your unique password and account information at all times.

Our Commitment to Data Security:

BetterLesson uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. BetterLesson may use encryption, secure socket layer, firewall, password protection and other physical security measures to help prevent unauthorized access to your personally identifiable information including sensitive data. BetterLesson may also place internal restrictions on who in the company may access data to help prevent unauthorized access to your personally identifiable information. These precautions take into account the risks involved in the processing, the nature of personally identifiable information, and best practices in the industry for security and data protection. We cannot, however, ensure or warrant the security of any information you transmit to BetterLesson, and you do so at your own risk. Once we receive your transmission of information, BetterLesson makes commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

If BetterLesson learns of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. BetterLesson may post a notice on the BetterLesson Platform if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive a free written notice of a security breach you should notify us at privacy@betterlesson.com. 

Accountability for Onward Transfer

BetterLesson is accountable for personally identifiable information that we receive and subsequently transfer to third parties. If third parties that process personally identifiable information on our behalf do so in a manner that does not comply with the Privacy Shield Principles, we are accountable, unless we prove that we are not responsible for the event giving rise to the damage.

Contact information and customer personally identifiable information is accessible only by those BetterLesson employees and consultants who have a reasonable need to access such information for us to fulfill contractual, legal and professional obligations. All of our employees and consultants have entered into confidentiality agreements, and/or have been subjected to thorough criminal background checks requiring that they maintain the confidentiality of customer personally identifiable information.

In the event BetterLesson discloses personally identifiable information covered by this Privacy Policy to a non-agent third party, it will do so consistent with any notice provided to data subjects and any choice they have exercised regarding such disclosure. BetterLesson will only disclose personally identifiable information to third-party agents that have given us contractual assurances that they will provide at least the same level of privacy protection as is required by this Privacy Policy and the Principles and that they will process personally identifiable information for limited and specific purposes consistent with any consent provided by the individual. If BetterLesson has knowledge that a third party to which it has disclosed personally identifiable information covered by this Privacy Policy is processing such personally identifiable information in a way that is contrary to this Privacy Policy and/or the Principles, BetterLesson will take reasonable steps to prevent or stop such processing. In such case, the third-party is liable for damages unless it is proven that BetterLesson is responsible for the event giving rise to the violation.

BetterLesson may use from time to time a limited number of third-party service providers, contractors, and other businesses to assist us in providing our solutions to our customers or in meeting internal business operation needs. These third-parties may access process or store personally identifiable information while performing their duties to BetterLesson. BetterLesson maintains contracts with these providers restricting their access, use and disclosure of personally identifiable information in compliance with our obligations under the Principles.

Our Commitment to Children’s Privacy:

If you are under 13 years of age, then please do not use or access THE BETTERLESSON PLATFORM at any time or in any manner.
Protecting the privacy of young children is especially important. For that reason, BetterLesson does not knowingly collect or maintain personally identifiable information from persons under 13 years-of-age. If BetterLesson learns that personally-identifiable information of persons less than 13-years-of-age has been collected on or through the BetterLesson Platform, then BetterLesson will take the appropriate steps to delete this information.

If you are the parent or legal guardian of a child under 13 who has become BetterLesson Platform member, then please contact BetterLesson at privacy@BetterLesson.com to have that child’s account terminated and information deleted.

The following are some resources that may help parents and legal guardians in monitoring and limit your children’s access to certain types of material on the Internet. While BetterLesson does not endorse these products, we provide information about them as a public service to our community.

International Visitors:

For Users visiting the BetterLesson Platform from the European Economic Area or other non-U.S. territories, please note that any data you enter into the BetterLessonPlatform will be transferred outside the European Economic Area or such other non-U.S. territory for use by BetterLesson and its affiliates for any of the purposes described herein. In addition, because BetterLesson operates globally, we may make information we gather available to worldwide business units and affiliates. By providing any data on the BetterLesson Platform, you hereby expressly consent to such transfers of your data to the United States or other countries.

In the Event of Merger or Sale:

In the event that BetterLesson is acquired by or merged with a third-party entity, we reserve the right, in any of these circumstances, to transfer or assign the information that we have collected from Users as part of that merger, acquisition, sale, or other change of control.

Changes and Updates to this Privacy Notice:

This Privacy Notice may be revised periodically without further notice to you and this will be reflected by a ‘last modified’ date below. Please revisit this page to stay aware of any changes. In general, we only use your personal information in the manner described in the Privacy Notice in effect when we received that personal information. Your continued use of the BetterLesson Platform constitutes your agreement to this Privacy Notice and any future revisions.

Enforcement and Liability

BetterLesson is subject to the jurisdiction and enforcement and investigatory authority of the United States Federal Trade Commission.

BetterLesson also commits to periodically reviewing and verifying the accuracy of this Privacy Policy and the company’s compliance with the Principles, and remedying issues identified. All employees of BetterLesson that have access to personally identifiable information covered by this Privacy Policy in the U.S. are responsible for conducting themselves in accordance with this Privacy Policy. Failure of an BetterLesson employee to comply with this Privacy Policy may result in disciplinary action up to and including termination.

BetterLesson assures compliance with this EU-U.S. and Swiss-U.S. Privacy Shield Policy and the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks by utilizing the self-assessment approach as specified by the U.S. Department of Commerce. The assessment is conducted on an annual basis to ensure that all of BetterLesson’s relevant privacy practices are being followed in conformance with this EU-U.S. and Swiss-U.S. Privacy Shield Policy and the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks. Any employee that BetterLesson determines is in violation of these policies will be subject to discipline, up to and including termination of employment and/or criminal prosecution.

BetterLesson Contact Information:

Please contact BetterLesson with any questions or comments about this Privacy Notice, your personal information, and our third-party disclosure practices or your consent choices at: BetterLesson, 84 Sherman St., Cambridge, MA 02140, or by email: privacy@betterlesson.com. We will respond to your inquiry within 30 days of its receipt.

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