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© 2016 Unleesh. Terms, conditions, features, availability, pricing, fees, service and support options subject to change without notice. iPad and iPhone are trademarks of Apple Inc., registered in the U.S. and other countries.

© 2016 by Unleesh, LLC

 

Privacy Policy

Effective 05.05.2015

Overview

 

Welcome to Unleesh! This Privacy Policy (the “Policy”) describes the collection, use and disclosure of information collected online by the Unleesh mobile application(s) (“App(s)”), the Unleesh website at www.unleesh.com (including any subdomains or websites where this Policy is posted) (each, a “Site”), and other Unleesh services (together with the App and Site, the “Platform”). This Privacy Policy forms an agreement between you and Unleesh, LLC (“Unleesh,” “us,” “our,” or “we”). Through your continued use of the Platform, you consent to the practices described in this Policy.

 

This Policy describes what information we may collect, how we may collect it, with whom we may share it, and other matters related to the information we collect, including your choices regarding collection and disclosure to third parties. This Policy is incorporated into our Terms of Use and may include terms that are defined in that agreement. Unless stated otherwise, this Policy only addresses the use and disclosure of information we collect from you online through the Platform, or offline, to the extent that the offline collection, use or sharing of such information is necessary to obtain or document any consents required before a user may use, or provide information to us through, our Platform.

 

Please note, for some services or features, we may collect and transfer information to a service provider or, where permitted, to our clients who control each Path, or with other partners, affiliates or entites. Additional Terms, or other agreements, laws or protections may apply to you and the information collected from you through our Platform (for example, if you access our Platform through your university or employer). Further, should you arrive at a third-party site or service when using our Platform, please take a moment review the privacy policies of those third-party sites before you disclose information to them.

 

What Information do we collect and how do we use it?

 

For the purposes of this Policy, “Personal Information” means any information that can be used to identify you as an individual, including your full name; address; online contact information, such as an email address, screen name or username; or any persistent identifier that can be used to recognize you over time and across different services; precise geolocation information; and any information about an individual linked to such identifying information.

 

Our Platform allows users to complete a series of structured learning objectives or “Paths.” Users make learning social by uploading their own content to demonstrate how they achieved a Path’s learning objectives. Using the Platform, users may write posts and upload pictures, audio or other content (collectively, “User Content”) to share their learning experience. Path access, content, and management is handled by the

Path’s creator and/or sponsor (an “Administrator”).

 

We may collect information on behalf of any client who controls a Path and share your Personal Information or User Content with them, as discussed further below.

 

When you register with us

 

When you register with us you provide certain Personal Information. For example, we may collect your profile photo, name, email address, your birthdate, information about your professional or educational background, your address, the gender with which you identify, and other Personal Information listed on the registration form. We may use this information to contact you on behalf of a Path Administrator, regarding our products and service, or as necessary to provide our service and to maintain your account.  We may also aggregate and anonymize your Personal Information to analyze user trends and create reports for our internal use, or that may be shared with third parties and marketers.

 

When you use a Path, you will also create a profile visible to all users of that Path, which may contain some, but not all, of the information you provided when you registered with us (“Profile Information”).  Your Profile Information may be shared with other users of a Path, or the public, as discussed below.

 

When you post content in a Path

 

By posting User Content to the Platform, you consent to the collection and any permitted sharing of the User Content and Personal Information you provide. Because the content in Paths may differ depending on the nature and scope of each Path, the Personal Information and User Content we may collect varies accordingly. If you provide User Content, we may collect certain metadata associated with or included as part of a file you upload, such as file size, time, date, and location. Do not provide any information or upload any files you do not wish to share with the group authorized to see your User Content as part of a given Path, which may include members of the general public.

 

When you use the App

 

Our Platform is accessible through our App on iOS, Android and other mobile operating systems. When you use our App, we may collect, as described above, any Personal Information and User Content you provide. We may also collect precise location information, and certain information about your device (such as the operating system version and device model) that we do not use to identify you personally. We may associate any location information you provide with your posts or other User Content if you consent to the collection of location information or allow geotagging of your User Content.

 

When you browse our Site

 

Our Site uses cookies and other similar tracking technologies that may be used to provide essential features or improve your experience when using our Site, as described further below. Our cookies and other tracking technologies do not generally contain Personal Information.

 

Additionally, our servers may identify users by their IP address (e.g. to determine the city from which you access the Site). An IP address is a number that is automatically assigned to your computer whenever you access the Internet. We may also log click-stream data for purposes of system administration, to improve our Site and App, and to report aggregate information to our clients and partners and/or other internal uses related to the Site. Click-stream data is information collected by our computers when you request pages from the Site or App. Click-stream data may include information such as the page served, the time, the source and type of browser making the request, the most recent page view, and other non-personal information. This data helps us analyze how visitors arrive at our Site, what type of content is most popular, what type of visitors in the aggregate are interested in particular kinds of properties, advertising, and the like.

 

If you sign up for our mailing list or other Site emails

 

We may offer a mailing list that provides information about the Platform, available Paths, us, our clients and partners, or other information we believe may interest you. If you sign up for these communications, we may collect Personal Information, such as your name and email address, so that we can send you personalized emails. Please note, you may receive communications either by requesting more information, or by allowing emails from us when you registered on the Platform.

 

If you contact us through the Site or for tech support

 

You may contact us using the form on our Site for tech support and other questions you may have. If you contact us using our Site, we will collect the Personal Information requested on the applicable form, typically your name and email address. All information you provide through the ‘contact us’ form is used only in the context of resolving your request or inquiry.

 

Cookies and tracking

 

Our Site may use cookies, web beacons and similar tracking technologies. These technologies are widely used for security, to learn about and improve upon how users navigate a website, to enable certain features, or to deliver relevant advertising content to you on the web. Cookies are small data files that are transferred to your hard drive when your browser settings permit the acceptance of cookies. Similar technologies, such as web beacons or pixel tags function through the use of small files, such as a GIF or PNG, which are opened on a page or in an email. The request for these files from a server reveals to the operator of that server (which may be a third party) certain information, such as your browser type, IP address, and other information. To learn more about cookies and similar tracking technologies, and how they can affect your privacy, visit allaboutcookies.org.

 

By tracking how and when you use our Site, these technologies help us determine which features and content on our Site are most important to our visitors. Accepting cookies allows you, among other things, to improve your experience using our Site, for example, by allowing your browser to store your password. If you do not want information collected through the use of cookies, you can turn off cookies using your browser’s settings menu; however, this may eliminate our ability to provide you with a personalized or user-friendly experience on our Site.

 

Please note, most modern browsers include a “do not track” feature that may help protect your privacy. However, because there is not yet a defined response to do-not-track requests, our Site does not respond to your browser’s do-not-track request.

 

Our Site does not currently contain cookies or technologies tracking users across third party sites, however we reserve the right to do so.  If you wish to take steps to opt-out of tracking by certain online advertisers, you can visit the Digital Advertising Alliance’s opt-out page at http://www.aboutads.info/choices. To learn more about, or to opt-out of Google’s analytic and marketing services, visit Google Analytics Terms of Use, the Google Privacy Policy, or Google Analytics Opt-out.

 

How is my Personal Information shared?

 

Your Personal Information and User Content may be shared differently depending on your choices, the settings of a Path, other users, and the laws applicable to you or your Personal Information. Generally, we share your Personal Information with and make your User Content accessible to a Path’s Administrator. The Administrator may be your employer, university, or any other organization or entity managing the Path.

 

Posts in a Path may be available to the public or limited to users of a private Path by default, depending on the choices of the Path creator and you. In a private Path, your User Content and Profile Information are visible to other users in the Path. In a public Path, your name, photo, place of study, employment, professional title, and any User Content you provide as part of your completion of that Path may be available to the Administrator and any other member of the public who registers with Unleesh and joins the Path.

 

If a Path is open to the public, any member of the public who registers with Unleesh and joins the Path will have access to your public posts. In private Paths, only users authorized by the Administrator (e.g. other users from your company or school) may have access to your public posts.  Further, other users may “track” your progress on a Path. In such cases, these users will be alerted to your posts, achievements and other information about your progress in any Path.

 

Please note, we may share Personal Information as part of other agreements you have entered and in which you granted consent for sharing (such as an agreement between you and your employer or educator). Remember to read other agreements that might affect the sharing of your Personal Information. We are not liable for any other party’s use, disclosure, or collection of your Personal Information.

 

In addition to your choices above, we may, without your consent, share any Personal Information and User Content we collect with third parties who provide essential services on our behalf, such as providers of data hosting or processing services, payment processors, or other service providers. We may also aggregate and anonymize information you provide us for internal use or in order to provide reports about our user base and Paths to third parties and marketers.

 

Finally, we may share any Platform Data or Personal Information we possess as part of a sale or transfer of our business, or substantially all of our assets. We might also share your Personal Information if we need to protect the interests of Unleesh, our customers, property, or the public. Similarly, we may share Personal Information with governmental authorities or otherwise in response to a legal request that we believe requires us to do so. We will share any such information to the extent we believe that request requires. Legal requests include, for example, search warrants, subpoenas, and other court orders. We may also receive legal requests or orders from jurisdictions outside the United States, in which case you consent for your Personal Information to be transferred to any applicable country.

 

What choices do I have about collecting, using, and disclosing my information?

 

When you upload User Content, you may be able to select whether to make your post public or private. You may limit e-mail communications from us or opt-out of receiving emails from third parties, or you can unsubscribe from email newsletters or similar communications by clicking on the unsubscribe link in every email. You may opt out of all information sharing with third parties for marketing purposes by contacting us at the address or email below and informing us of your request.

 

How can I access or update my Personal Information?

 

You may access your User Content and Profile Information through our Platform by logging into your profile. You can update or change your Profile Information, password, and other information using the “Me” menu of your profile. To obtain a list of the personal information that Unleesh holds about you, or for residents of California (as required by California law) the personal information Unleesh has disclosed about you to third parties for direct marketing purposes during the preceding calendar year (if any) please send a written, signed request to:

 

Unleesh, LLC

Attn: Privacy

50 South Steele Street, Suite 328

Denver, CO 80209

 

For access to any other Personal Information, or if you have questions, please contact us using the information below.

 

Is my Personal Information protected?

 

We use reasonable security measures to protect any Personal Information held by Unleesh. We implement and regularly review various physical, procedural and technological safeguards that we believe will keep your Personal Information secure. While we use reasonable efforts to ensure that third parties will safeguard and use your Personal Information in accordance with this Privacy Policy, we cannot make any representations or guarantees about the practices of other parties.

 

Links to third-party sites

 

You should be aware that when you use our Site you could be directed to other sites beyond our control. For example, if you click on a link to one of our service providers, partners or other third-party content, you will likely leave our Site and move to a different website which is not operated by us. These other websites may use cookies, independently collect data or solicit Personal Information, and may or may not have their own published privacy policies. If you visit a website that is linked to our Site, you should carefully review that site’s privacy policy before providing any Personal Information. This Policy does not apply to any information you submit to third-party websites, including, without limitation, any websites that may be connected to our Site by hypertext link or otherwise.

 

COPPA compliance and the rights of parents

 

Unleesh is committed to compliance with the U.S. Children’s Online Privacy Protection Act (“COPPA”). Our Platform is intended for general audiences, such as educators and parents, and is not directed to children.  If we discover that one of our users is under the age of 13, in accordance with the Children’s Online Privacy Protection Act (“COPPA”), we will not collect, use or share any of the child’s personal information (as defined by COPPA) unless we first notify the child’s parent and obtain the parent’s consent as required by COPPA.  However, we reserve the right to block access to certain features of our Platform (and any associated collection of personal information) if we learn that a child is under age 13, rather than seeking parental consent as described above. 

 

If a child under the age of 13 were to use our Platform, because our Platform is designed for general audiences, the personal information collected from the child would be the same as that collected from adults, as described elsewhere in this Privacy Policy. Parents should be aware that our Platform may include social media sharing features. If a child were to use these features of our Platform, the child could potentially disclose personal information to other users of all ages via those services.  Please be aware of any privacy policies of these third party social media sites before allowing your child to use them.

 

Parents have the right to review, edit, request the deletion, or prevent further collection or use of their children's personal information.  Parents may also choose to agree to the collection and use of their child’s information, but not allow disclosure of such information to third parties unless it is inherently part of the Platform, in accordance with COPPA.  Parents may request any of these actions, or make inquiries regarding our privacy practices, by sending an email to contact@unleesh.com or writing to us at the address below.

 

International guests

 

If you are accessing this Platform from outside of the United States, you consent to the transfer of your information to the United States, and the processing, use, and sharing of your information in accordance with this Privacy Policy. Regardless of where your information is collected or transferred, the information will be treated in accordance with this Privacy Policy.

 

US-EU/US Swiss Safe Harbor

 

We comply with the US-EU and US-Swiss Safe Harbor Frameworks. These US Department of Commerce frameworks relate to the collection, use and retention of personal information collected from users in the European Union and Switzerland. We adhere to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access and enforcement. To learn more about the Safe Harbor programs, please visit http://www.export.gov/safeharbor/.

 

Any questions or concerns about our privacy practices should be sent to the address or email below. We will investigate and attempt to resolve any complaints and disputes regarding the use and disclosure of Personal Information in accordance with the provisions of this Privacy Policy. We have agreed to participate in the dispute resolution procedures of JAMS to resolve disputes pursuant to the Safe Harbor Privacy Principles. EU residents with unresolved complaints may refer them to the JAMS as described at http://www.jamsadr.com/file-safe-harbor-claim/.

 

You can view our EU-US Safe Harbor certification page here, and our US-Swiss Safe Harbor certification page here.

 

Limitation of liability

 

By providing us with any Personal information you expressly and unconditionally release and hold harmless Unleesh, its parents, subsidiaries, affiliates, related companies and their respective shareholders, owners, members, directors, officers, employees and agents (collectively, the “Releasees”) from any and all liability for any injuries, loss or damage of any kind arising from or in connection with the use and/or misuse of your collected Personal Information. In addition, while we take reasonable steps to prevent third-party companies from making unauthorized use of your personal information, we cannot be held liable for any injuries, loss or damage of any kind arising from or in connection with the use and/or misuse of your collected Personal Information or User Content by those third parties.

 

Changes to this policy

 

This policy may change from time to time. We post the current privacy policy and its effective date on our website at www.unleesh.com and in our App. If we think we need your express consent following any changes, then we will notify you. Your continued use of the Platform after we make any changes, indicates that you continue to agree and consent to the modified version of this policy.

 

Questions?

If you have any questions or need any information about Unleesh, our collection and use of Personal Information, or our data protection practices, please contact us at:

 

Unleesh, LLC

Attn: Privacy

50 S. Steele St., Suite 328

Denver, CO 80209

contact@unleesh.com