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The KWL Hub Canada Privacy Policy

Klett World Languages Learning Platform – Privacy Policy

Last Updated: March 1, 2024

1. Introduction

Klett World Languages Canada Inc. (together with its subsidiaries, divisions, and brands, collectively, the “Company,” “us,” “we,” or “our,” as the context may require) provides access to online instructional materials and Learning Management System functionalities through The KWL Hub operated and provided by Klett World Languages, Inc., at https://klettlp.com, along with The KWL Hub mobile device application (the “App“). This Privacy Policy (this “Policy“) describes our privacy practices for the Site and the App (together, the “Services“), including the types of information we may collect from you when you visit or use the Services and our practices for collecting, using, protecting, and disclosing that information. We respect the privacy of the users of the Services (“you” or “your,” as the context may require) and we are committed to protecting your privacy and the security of your personal information through compliance with this Policy.

Please read this Policy carefully to understand our practices regarding your personal information. By accessing or using the Services, you agree to this Policy and our Terms of Use. If you do not agree with our policies and practices, please do not visit, access, use, or otherwise interact with the Services.

2. Authorization

If you are a student in primary or secondary school or if you are under 18 years old and not sure whether you are old enough to agree to this Policy, please do not use the Services, unless your parent or legal guardian set up your account, registered you to use the Services, or otherwise consented to your setting up an account or registering to use the Services.

The Company otherwise receives authorization to collect, use, and disclose personal information under this Policy when a user (a) purchases the Services; (b) establishes an account or registers to use the Services; or (c) uses the Services.

3. The Interactions this Policy Covers

This Policy describes and applies exclusively to personal information (as defined below) that we collect on or in connection with the Services and in SMS, emails, and other electronic communications sent through or in connection with the Services. Except as otherwise provided in this Policy or as required by applicable law, this Policy does not apply to information that is collected by any application, website, or third party other than the Services, including through any application or content that may access, be linked to, or otherwise be accessible from the Services. If you visit an application, website, or third party that we mention or link to, be sure to review its privacy policy before providing it with any
information, as that privacy policy will apply to your interactions with that application, website, or third party.

Except as otherwise provided in this Policy, “personal information” includes any factual or subjective information, recorded or not, that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, to an identifiable individual. “Personal information” does not include information which is generally not considered “personal information” under applicable law or is otherwise exempted under applicable law.

4. Information We Collect

We collect several types of information from and about you as a result of your use of or registration with the Services and as a result of your communication with us. This information may include:

Various categories of personal information, such as:
- Identifiers, including your name, username, age, physical address, email address, phone number, and other similar identifiers.
- Education information, including grade, course information, class lists, and other records maintained by a School and directly related to a student.
- Location information, to the extent it can be approximately derived from your IP address.
- Professional or employment information, such as the school you currently work for, and also education and work history when you apply to work with us.
- Inferences drawn from any of the above.
- Any other personal information that you upload or share to or on the Services, or which you otherwise provide directly to us.
Information that is about you but individually does not identify you, such as information which has been de-identified or aggregated in a manner where it can no longer be used to identify you.
Information about your internet connection and the equipment you use to access the Services; IP address, approximate location, and other unique device identifiers; your activity on the Services; and other usage details collected through your use of the Services.
Any other information, including personal information, which you disclose or share.

5. How We Collect Personal Information

We may collect personal information:

Directly from you when you provide it to us;
Directly from your School, parent, or legal guardian; and
Automatically when you use or access the Services.

A. Information We Collect Directly

The personal information we collect directly from you when you use or access the Services includes:

Information that you provide by filling in forms on the Services. This includes information provided at the time of requesting further information or reporting a problem with the Services.
User profile information provided at the time of registering to use the Services and throughout the period when you are logged into the Services.
Your voluntary responses to surveys that we might ask you to complete.
Details of transactions you carry out through the Services and of the fulfillment of your orders.
Your search queries on the Services.
Records and copies of your communications when you contact us.

If you are a student, we may also collect information about you directly from your School, parent, or legal guardian, such as when they register you to use the Services.

B. Information We Collect Automatically

As you navigate through and interact with the Services, we may use automatic data collection technologies to collect certain information, including:

Usage details. When you access and use the Services, we may automatically collect certain details of your access to and use of the Services, including traffic data, approximate location data, logs, and other communication data and the resources that you access and use on or through the Services.
Device information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, and mobile network information.

The information we collect automatically is only statistical data and does not, in and of itself, include personal information, but we may maintain it or may associate it with other personal or business information we collect in other ways or receive from third parties. This information helps us to improve our Services and to deliver a better and more personalized service, including by enabling us to:

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Services according to your individual interests.
Speed up your searches.

The technologies we use for automatic information collection include cookies. A cookie is a small file placed on the hard drive of your computer. We use session-based cookies, which are cookies that last only while your browser is open and are automatically deleted when you close your browser. You may refuse to accept cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Services, and overall functionality of the Services may be impaired. For example, refusing to accept cookies may not allow you to stay signed into the Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Services.

C. From Third Parties

We may also receive personal information or draw inferences about you from other sources, including, without limitation, service providers who collect or process information on our behalf. We generally require these service providers to use your personal information only as we direct and in a manner consistent with this Policy.

6. How We Use Your Personal Information

We may use the personal information that we collect about you or that you provide to us:

To provide you with the Services, all related content, and any other information, products, or services that you request from us.
To create, manage, maintain, and secure your account and to provide you with notices about your account.
To communicate with you and to process your requests.
To give you notices about your account.
To notify you of changes or additions to any products or services we offer through the Services.
To notify you to participate in interactive features of the Services.
To help maintain the safety, security, and integrity of the Services, as well as our products, services, databases, and other technology assets.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
For testing, research, analysis, and product development, including to understand our audience, develop and improve the Services, as well as our customer service, products, and services.
To respond to law enforcement requests and, as required by applicable law, court order or governmental regulations.
To evaluate, negotiate, or conduct a merger, divestiture, restructuring, reorganization, dissolution, other sale or transfer of some or all of our assets, or the negotiation thereof, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users and customers is among the assets transferred.
To fulfill any other purpose for which you provide it.
For any other purpose with consent.

7. Disclosure of Your Information

We may disclose personal information that we collect or that you provide from any category identified above in Section 4 (Information We Collect):

To our subsidiaries and affiliates.
To our software and hosting provider, Magic EdTech. Its privacy policy can be viewed at https://www.magicedtech.com/privacy-policy.
To contractors, service providers, advisors, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
To an actual or perspective buyer or other successor in the event of an actual or proposed merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users is among the assets transferred.
To fulfill the purpose for which you provide it.
To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce our rights arising from any contracts entered into between you and us, and for billing and collection.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.
For any other purpose disclosed by us when you provide the information.
With your consent.

We may use or disclose aggregated information about our users and information that does not identify any individual without restriction.

8. Google Application Programming Interface (API) Services Disclosure

The KWL Hub’s use and transfer to any other application of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

The Site’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.

9. Your Privacy Rights

We provide all users with rights to:

Confirm whether we process their personal information.
Access, correct, and delete certain personal information.
Data portability.
Opt-out of personal data processing for targeted advertising and sales.
Opt-out of certain types of profiling.

To exercise any of these rights, please contact us using the information set forth in Section 14 (How to Contact Us) below. We may deny a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect, and we may retain copies of your personal information to the extent required by applicable law.

To appeal a decision regarding a consumer rights request, please contact us as set forth in Section 14 (How to Contact Us).

10. Other Privacy Choices

We strive to provide you with as many choices as possible regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Account Access. You can review, change, and remove some of your personal information by logging into the Services and visiting your account profile page.

Tracking Technologies. You can set your browser to refuse all or some cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, some parts of the Services may then be inaccessible or not function properly.

Promotional Offers from Us. If you do not wish to have your contact information used by us to promote our own products or services, you can opt-out by unsubscribing from any emails you receive from us. Additionally, you can also always opt-out by contacting us as provided in Section 14 (How to Contact Us). We will not send promotional offers to any users.
Accessing and Updating Your Information. To update your information (such as name or email address), you can review and change some of your personal information by logging into the Services and visiting your account settings page. You may also contact us as provided in Section 14 (How to Contact Us) to update your information.

11. Security

We implement various physical, administrative, and technical safeguards in accordance with industry standards to protect the security of your personal information both online and offline. The safety and security of your information also depends on you. Where you have a password for access to certain parts of the Services, you are responsible for keeping this password confidential. Do not share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

12. Changes to this Policy

We reserve the right to review and revise this Policy from time to time, without prior notice, subject to applicable legal requirements to provide you prior notice or obtain your consent. The date this Policy was last reviewed and/or revised is noted at the top of the page. You are responsible for periodically visiting the Services and this Policy to check for any changes. Your continued use of the Services following the posting of changes constitutes your acceptance of such changes.

13. How to Contact Us

To ask questions or comment about this Policy and our privacy practices, you may contact us:

Via mail at 320 W. Ohio St. Suite #3W, Chicago, Il 60654
Via phone at 1-844-553-8895
Via email at [email protected]