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Privacy Policy

Last Updated and Effective as of December, 2020

CLCD, LLC and its affiliates (“CLCD,” "we," "us," or "our") take your privacy seriously. This Privacy Policy explains what information we collect through our web sites, mobile applications or online services that link to this Privacy Policy (each, a "Site"), how we will use, disclose and protect this information, and how you can opt out of some of our uses and disclosures of your information. This Policy does not apply to information that we collect in other ways, such as over the phone, by mail, or in person, except where we specifically state otherwise or as required by law.


IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, YOU SHOULD NOT ACCESS OR OTHERWISE USE THE SITE.


WHAT INFORMATION IS COLLECTED ON THIS SITE?

Personal Information

"Personal Information" is information that can be used to specifically identify an individual. We may collect Personal Information from you, about you or someone else, when you submit it voluntarily. Categories of Personal Information we collect include:

  • Identity Data, which includes name or other similar identifiers
  • Contact Data, which includes postal or physical address, email address, telephone number
  • Financial Data, which includes credit card and other payment information

Additionally, we may also collect certain other types of information that, along with Identity Data, Contact Data and Financial Data may be considered and specifically named “Personal Data” in certain jurisdictions, including the European Union (“EU”), such as:

  • Technical Data, which includes, general and precise geographic location information, your Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our Sites (e.g., HTML pages, graphics, etc.), search terms, type of device used, device or advertising identifiers, statistical identifiers, operating system, and date/time stamp.
  • Usage Data, which includes your interaction with our Site such as movement, scrolling, time spent on certain features or actions, and/or clickstream data to analyze trends in the aggregate and administer and improve the Sites.
  • Marketing and Communications Data, which includes your preferences in receiving marketing from us. Provision of your information to us is not a statutory or contractual requirement. Where we need to collect your information by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we will not be able to provide services to you.

HOW IS YOUR INFORMATION COLLECTED?

Direct Interactions

You may give us your information by interacting with our site and submitting your information directly.

This includes information you provide when you:

  • create an account;
  • subscribe to our service or publications;
  • request marketing be sent to you;
  • enter a competition, promotion or survey;
  • make a purchase;
  • comment on content;
  • contact customer service;
  • give us feedback; or
  • apply for a job.

Tracking Technologies

CLCD uses cookies, local storage, pixel tags, web beacons and other technologies to receive and store certain information. Cookies are small data files that our Sites send to your browser that are then saved on your computer or device. You can control the use of cookies through settings at the individual browser level, but if you disable cookies, it may limit your use of our Sites. For more information about cookies, go to https://www.allaboutcookies.org/.

Local shared objects, such as "Flash cookies," may be stored on your computer or device through a media player or other installed software. Local shared objects operate a lot like cookies, but cannot be managed in the same way. You may be able to manage Flash cookies and other local storage using browser, software or device settings. For information on managing Flash cookies, go to: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html As you use the Internet, a trail of electronic information is left at each website you visit. This information, sometimes referred to as "clickstream data," can be collected and stored by our Site’s servers. Our collection of clickstream data is not used for personal identification purposes. As described under “How Your Information Is Used and Disclosed” section, we use these technologies to help us remember you and enhance your use of our Sites, to manage and analyze service usage, and to promote content, products and services based on that usage. We may do this through third parties like advertising or analytics companies (e.g., Google Analytics, Google AdWords, Omniture, DoubleClick, OwnerIQ and Mouseflow).


Third Parties

We may get your information from third parties such as other users, advertising networks, data brokers or social media platforms.


HOW IS YOUR INFORMATION USED AND DISCLOSED?

Our Use of Your Information

We may use or disclose your information for these purposes:

  • To authenticate users
  • To maintain and administer the Site and user accounts
  • To process and fulfill transactions and respond to customer requests
  • To analyze the Site, monitor Site performance and diagnose Site issues
  • To perform customer service and troubleshoot customer service calls about difficulty using the Site
  • To improve the Site and develop new features and products
  • To send email marketing and other communications, including information about products, services, and events, of ours and of others
  • To personalize customer’s experience of our Site based on user interests and history with us (for example, remembering items in bookshelf, or providing a consistent Site experience across multiple devices)
  • To provide location-based services
  • To match your information with other data or supplement your information with other data that we may obtain directly or through third parties
  • To evaluate applications for employment
  • When you otherwise consent to a particular usage
  • To protect our rights and property and the rights, property, and safety of others
  • To investigate suspected fraud or other unlawful activity
  • Where otherwise permitted or required by applicable law.

Service Providers

Our third party vendors and subcontractors may access your information to provide services for us, including: fulfilling orders and delivering packages, payment processing, providing customer service, hosting and serving content and general website operations, sending marketing communications, fulfilling subscription services, and conducting research and analysis. These vendors and subcontractors can only use your information as specifically allowed by us.

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Affiliates, Promotional Partners and Other Third Parties If you are not situated in the EU, we may allow our affiliates and promotional partners to use your Personal Information for their marketing and related purposes, including our co-sponsor(s), if we receive Personal Information through a contest, sweepstakes, offering or other activity that is jointly offered by us. If you are situated in the EU, please see the section “Additional EU Disclosures” for how we use your Personal Data for marketing.


Targeted Advertising

We or our third party partners may use some of the tracking technologies described above, such as plug-ins, cookies and non-cookie technology, to deliver targeted advertising to you when you visit other web sites or our Site. For more information on Targeted Advertising, please see the section titled “Targeted Advertising Opt Out.” We do not engage in targeted advertising on our Children’s Accounts or Sites.


Corporate Changes

We may transfer your information in connection with a corporate change or dissolution, including for example a merger, acquisition, reorganization, consolidation, bankruptcy, liquidation, sale of assets or wind down of business; and due diligence related to these events.


Legal Obligation

We may disclose or transfer your information in connection with a legal or regulatory obligation.


Anonymized Information

We may share anonymized data with others, for their own use, in a form that does not include your name or contact information.


OPT OUT

Opt-Out of Communications from Us and Modifying your Account You may have the right to opt out of certain uses and disclosures of your information by emailing us your request at customerservice@Clcd.com. We will comply with these requests consistent with applicable law. You may also opt out of receiving marketing emails from us by clicking on the opt-out link in those emails.

Nevada residents: We do not sell “Covered Information” as defined under Nevada law. If you would like more information about our practices with respect to Covered Information under Nevada law, please contact us at privacy@Clcd.com.

You can review, change or delete your information in your user account on the Site (if you have one) by logging in to your Accouny or a similar area of the Site, or by contacting us using the "Contact Us" information below. We may ask you to verify your identity before we provide you with your information or make changes to it. We reserve the right to keep certain information necessary for record-keeping to the extent permitted and/or required by law, including any statutory retention requirements.

To opt out of being tracked by Google Analytics, visit http://tools.google.com/dlpage/gaoptout. To opt out of Mouseflow session replay analytics, visit https//mouseflow.com/opt-out.

Even if you opt out of targeted advertising, you may continue to see generic advertising that is not tailored to your specific interests and activities. Please note, cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted out on your desktop computer’s browser, that opt-out will not be effective on your mobile device.


Do Not Track

Please note that we do not respond to or honor “do not track” (a/k/a/ DNT) signals or similar mechanisms transmitted by web browsers. For more information about “do not track”, go to https://allaboutdnt.com/.


SECURITY AND RETENTION

We follow generally accepted standards designed to protect your information and have in place appropriate security measures designed to prevent your information from being accidentally lost or used or accessed in an unauthorized way. We use appropriate security measures while your information is in transit and at rest, including encryption. You can verify whether a website is secure by looking for “https” at the beginning of the web address of the Site page you are on.

No website, however, can guarantee that information will be absolutely safe from intrusion or other unauthorized access. Except as expressly required by applicable statute or regulation, we will have no liability for disclosure of information due to errors or unauthorized acts of third parties during or after transmission.

We typically keep information related to marketing activities for as long as you accept marketing communications from us, and on request, we will securely delete such data in accordance with applicable law. For information that we collect and process for other purposes, as described above, we typically keep such information for the period necessary to fulfill the purposes outlined in this Privacy Policy, and as otherwise needed to address tax, corporate, compliance, litigation, and other legal rights and obligations. In some cases we may de-identify your data instead of deleting it.


SOCIAL NETWORKING SITES AND OTHER WEBSITES, APPS AND SERVICES

We use social networking platforms, such as Facebook, Twitter and Instagram, to communicate with our customers and integrate social networking services with our Site. Information you voluntarily submit to or post in a publicly accessible social network or other online forum may be viewed and used by others. Our Site may also contain links, banners or ads that lead to other third party sites, apps or services. We cannot control such third party uses of your information, so by using or navigating to those services, you assume that risk.

We encourage you to read the policies and terms of every web site, app or service you visit.


ADDITIONAL EU DISCLOSURES

IF YOU ARE SITUATED IN THE EU, THIS SECTION APPLIES TO OUR COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA AND ADDITIONAL RIGHTS YOU HAVE UNDER APPLICABLE LAW.


Data Controller


CLCD, LLC is the data controller of all Personal Data collected through our Site. If you are situated in the EU and have any complaints regarding our privacy practices, you have the right to make a complaint at any time to your local supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach your supervisory authority so please contact us in the first instance. If you have a complaint, please contact us at: privacy@Clcd.com.


Legal Basis of Processing


Some jurisdictions require an explanation of the legal basis for the collection and processing of your Personal Data. We have several different legal grounds on which we collect and process Personal Data, including: (1) as necessary to perform a contract (which may include responding to your requests); (2) as necessary to comply with a legal obligation (such as when we use Personal Data for record keeping to satisfy legal and compliance obligations); (3) consent (where you have provided consent as appropriate under applicable law, such as for marketing); and (4) necessary for legitimate interests (such as when we act to maintain or improve our business generally or to prevent fraud) to the extent permitted by law.


Affiliates, Promotional Partners and Other Third Parties We strive to provide you with choices regarding certain uses of your information, particularly around marketing and advertising:


  • Promotional offers from us: We may use your information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You may receive marketing communications from us ifyou have requested information from us or used our services and, in each case, you have not opted out of receiving that marketing.
  • Third-party marketing: We will get your express opt-in consent before we share your information with any company outside our company for marketing purposes. To see how you can opt out of marketing communications, please see the “Opt Out” section above.

Data Subject Access Rights

If you are a situated in the EU, under the General Data Protection Regulation (“GDPR”), as a data subject, you have the right to:


  • Request access to your Personal Data (commonly known as a "data subject access request").
  • Request correction of the Personal Data that we hold about you.
  • Request erasure of your Personal Data where there is no good reason for us continuing to process it; where you have successfully exercised your right to object to processing (see below); or where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law.
  • Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your Personal Data in certain scenarios.
  • Request the transfer of your Personal Data to you or to a third party. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • To exercise your rights under the GDPR, please contact us at privacy@Clcd.com.

Withdrawing your consent

If we are relying on your consent to process your Personal Data, you have the right to withdraw your consent at any time. You have the right to withdraw your consent at any time by contacting us at privacy@Clcd.com.


Data Transfer

Information provided to or collected by us on our Sites is transmitted to us and processed in the United States and other countries, either by us or our service providers on our behalf, and will be protected subject to this Privacy Policy and applicable laws, which may not be as protective as the laws in other countries. To the extent permitted by law, your use of the Site or provision of any Personal Information constitutes your consent to the cross-border transfer of Personal Data and the other activities identified in this Privacy Policy.

Please contact us at privacy@Clcd.com. if you want further information on the specific mechanism used by us when transferring your information out of the EU.


CALIFORNIA PRIVACY NOTICE / YOUR CALIFORNIA PRIVACY RIGHTS

Last Updated and Effective as of: December 31, 2019 This California Privacy Notice does not apply to Personal Information we collect from job applicants or independent contractors, or from our current or former full-time or part-time and temporary employees and staff, officers, directors or owners. This California Privacy Notice also does not apply to any Personal Information collected by us in connection with our educational software products. Requests for access to Personal Information collected through our educational software products should be directed to your school district.


California Consumer Privacy Act

As required by the California Consumer Privacy Act of 2018 (“CCPA”), we are providing the following details, in addition to those set out in the rest of our Privacy Policy, regarding the categories of Personal Information (as defined under the CCPA, and including applicable Personal Information collected online or offline, “CCPA Personal Information”) about California residents that we have collected or disclosed within the preceding 12 months.


What We Have Done in the Preceding 12 Months

(1) We collected the following categories of CCPA Personal Information:
A. Identifiers, such as name, contact information, online identifiers;
B. Personal information, as defined in the California customer records law, such as name, contact information, signature, payment card number or other payment information, employment information; C. Geolocation data, such as device location and IP location;
D. Audio, electronic, visual and similar information, such as call and video recordings;
E. Inferences drawn from any of the CCPA Personal Information listed above to create a profile/summary
about, for example, an individual’s preferences and characteristics. As described above in our general Privacy Policy, we collected this CCPA Personal Information from you and/or from other categories of sources such as data brokers. Also as described above, we may use this CCPA Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including, for example, to: develop, improve, repair, and maintain our products and services; personalize, advertise, market, sell and distribute our products and services; communicate with customers; conduct research, analytics, and data analysis; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions, such as internal investigations; comply with law, legal process, and internal policies; maintain records; and exercise and defend legal claims.

(2) We disclosed the following CCPA Personal Information to third parties for our operational business purposes: A. Identifiers, such as name, contact information, online identifiers;
B. Personal information, as defined in the California customer records law, such as name, contact information, signature, payment card number or other payment information, employment information;
C. Commercial information, such as transaction information and purchase history;
D. Internet or network activity information, such as browsing history and interactions with our website;
E. Geolocation data, such as device location and IP location;
F. Audio, electronic, visual and similar information, such as call and video recordings;
G. Professional or employment-related information, such as work history and prior employer; and H. Inferences drawn from any of the CCPA Personal Information listed above to create a profile/summary about, for example, an individual’s preferences and characteristics.
We shared CCPA Personal Information with our affiliates, service providers, third-party sponsors of and prize providers for sweepstakes, contests, and similar promotions, and our business partners, for our operational business purposes.


(3) We do sell user information

What You Can Do

If you are a California resident, you have the right to request that we:

(1) Disclose to you the following information covering the 12 months preceding your request:

The categories of CCPA Personal Information we collected about you and the categories of sources from which we collected such CCPA Personal Information;

  • The specific pieces of CCPA Personal Information we collected about you;
  • The business or commercial purpose for collecting or selling (if applicable) CCPA Personal Information about you;
  • The categories of CCPA Personal Information about you that we sold and the categories of third parties to whom we sold such CCPA Personal Information (if applicable); and
  • The categories of CCPA Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such CCPA Personal Information (if applicable).

(1) To make a request for any of these disclosures, please fill out the CCPA Request to Know Form https://www.clcd.com/ccpa-data-access.

(2) Delete CCPA Personal Information we collected from you. To make a request for data deletion, please fill out the CCPA Request to Delete Form https:// www.clcd.com/ccpa-data-deletion. We will respond to your requests consistent with applicable law. We may need to verify your identity. You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

Children’s CCPA Personal Information


Under the CCPA, sale of CCPA Personal Information of children ages 13 through 16 requires opt-in consent from the child. CCPA Personal Information under the age of 13 cannot be sold without parent or guardian permission. We do not knowingly sell children’s CCPA Personal Information. CLCD’s child-directed Site is governed by our CLCD Kids Privacy Policy, not this Privacy Policy.

Your California “Shine the Light” Rights


California residents have the right to opt out of disclosures of Personal Information (collected online or offline) to third parties for their direct marketing purposes. You can exercise that right by emailing us at customerservice@CLCD.com or by completing this Third-Party Opt-Out Form https://www.CLCD.com/opt-out. We will comply with these requests consistent with applicable law. You may also opt out of receiving marketing emails from us by clicking on the opt-out link in those emails.

California Minors


If you are a resident of California, under 18, and a registered user of the Services, you may ask us to remove content or information that you have posted to the Services by writing to customerservice@CLCD.com. Please include a description of the content you would like removed, and if possible, the URL for the site and the name of the feature where the content was posted. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.

Changes to this California Privacy Notice


We may change or update this California Privacy Notice from time to time. When we do, we will post the revised California Privacy Notice in this section or as otherwise required by law, with a new “Last Updated” date.

CHANGES TO THIS PRIVACY POLICY


We may update this Privacy Policy to reflect changes to our information practices or our business. If we make any material changes we may notify you by email (sent to the e-mail address in your account) and/or by a notice on this Site when the change becomes effective, unless otherwise required by applicable law.

CONTACT US

CLCD, LLC is the data controller of all Personal Information and Personal Data collected through the Site. You may contact us at:

CLCD-Content
322 Shore Road
Somers Point, NJ 08244
U.S.A.
Phone: 1-888-611-2523
Email – Customer Service: customerservice@CLCD.com
Email – Privacy: privacy@CLCD.com