Privacy Policy

Privacy Policy for Smart Edoo:

Smart Edoo and each Member that provides courses through the Smart Edoo Site care about the confidentiality and security of your information. This Privacy Policy applies to information that Smart Edoo collects through the Smart Edoo Site when you interact with Smart Edoo, with Members, with other users, and generally with the Smart Edoo Site.

Your information is received and controlled by Smart Edoo according to this Privacy Policy when you sign up for an Smart Edoo account or otherwise use the Smart Edoo Site.

★ Smart Edoo is solely and independently responsible for its own privacy practices. No Member is responsible for Smart Edoo’s privacy practices.

If you enroll in a course offered by a Member through the Smart Edoo Site, information about you and your activity in the course is received and controlled also by that Member as described in this Privacy Policy.

★ Each Member is solely and independently responsible for its own privacy practices. No Member is responsible for another Member’s privacy practices. Also, Smart Edoo is not responsible for any Member’s privacy practices.

If you do not accept the terms of this Privacy Policy, then please do not access, browse, or register for the Smart Edoo Site or enroll in any courses. If you choose not to provide certain information required to provide you with various products and services offered on the Smart Edoo Site, then you may not be able to establish a user account or obtain those products or services.

Any version of this Privacy Policy in a language other than English is provided for convenience and you understand and agree that the English language version will control if there is any conflict.

This Privacy Policy is organized as follows:

·       Information that Smart Edoo collects from you (including Personal Information)

·       Cookies and Tracking Technologies on the Smart Edoo Site

·       How your information is used

·       How your information is shared

·       How to manage your Personal Information

·       Storage & Security

·       Privacy Policy updates

·       Contact information

·       Glossary

INFORMATION THAT SMART EDOO COLLECTS FROM YOU (INCLUDING PERSONAL INFORMATION)

Smart Edoo directly collects information when you:

·       sign up for an Smart Edoo user account and create an Smart Edoo user profile;

·       enroll and participate in online courses;

·       purchase a product or service (for example, Paid Classes);

·       send email messages to Smart Edoo (including messages to learner support);

·       participate in user surveys; and

·       participate in public forums, webinars, and other interactive experiences on the Smart Edoo Site.

Smart Edoo also indirectly collects usage information about your visit to the Smart Edoo Site, as explained in the section below titled Cookies and Tracking Technologies.

Smart Edoo does not itself collect or store financial account numbers or identification issued by a governmental entity, employer, or other authority. Instead, if you choose to make a purchase on the Smart Edoo Site, for example a Verified Certificate, you will be directed to Smart Edoo’s third-party payment processor and Smart Edoo’s third-party ID verification service provider. If you do not wish to submit the required authentication or payment information, then you will not be able to obtain a certificate via the Smart Edoo Site.

Smart Edoo requires your Personal Information only in limited circumstances when you:

·       sign up for an Smart Edoo user account (name, username, email address);

·       purchase a Verified Certificate (so that Smart Edoo’s third-party vendor can authenticate your identity) or other product or service (so that Smart Edoo’s third-party vendor can process payment);

·       participate in remote proctoring or other course facilitation processes (so that Smart Edoo’s third-party vendor can monitor and assess the integrity of your course activity); or

·       earn a Verified Certificate (the certificate will have your name on it).

To the extent that Smart Edoo associates the information that Smart Edoo collects directly or indirectly with an individual (for example, you), the association is based on Personal Information in your account profile.

You may voluntarily choose to share additional Personal Information on the Smart Edoo Site, for example:

·       in your Smart Edoo account profile (and you may display a limited or full profile to other Smart Edoo Site users);

·       in applying for financial assistance; or

·       when participating in a course, forum, webinar, or other interactive experience on the Smart Edoo Site (noting that in some cases, this information is shared with a third party that provides tools or other assistance for the Smart Edoo Site or a course).

Smart Edoo encourages you to use discretion before voluntarily sharing additional Personal Information on the Smart Edoo Site. (If you later choose to delete your Smart Edoo account, deletion of your Personal Information will be subject to the process and limits outlined below.)

Members do not receive your Personal Information unless and until you enroll in a course. If you enroll in a course, the Member that offers the course will receive Personal Information from your Smart Edoo account profile plus the information that Smart Edoo collects about your activity and performance in the course in which you enrolled.

COOKIES AND TRACKING TECHNOLOGIES ON THE Smart Edoo SITE

Like many companies, Smart Edoo uses Cookies and other common Tracking Technologies on the Smart Edoo Site and in email communications to help Smart Edoo better understand your use and needs of the Smart Edoo Site, current and future Smart Edoo-related products and services, and how Smart Edoo and Members can improve. For example:

·       based on your cookie settings, Smart Edoo tracks information indicating, among other things, which pages of the Smart Edoo Site were visited, the order in which they were visited, when they were visited, and which hyperlinks and other user interface controls were used;

·       Smart Edoo may log the IP address, operating system, and browser software (including mobile use and device type when you use Smart Edoo native mobile apps) you used when accessing the Smart Edoo Site, and Smart Edoo may be able to determine from an IP address your Internet Service Provider and the geographic location of your point of connectivity; and

·       Smart Edoo may track and collect information from emails that Smart Edoo sends to you, for example whether you opened the email or clicked on any links from the email.

Smart Edoo also partners with third parties to help us track and understand your activity on the Smart Edoo Site, how you interact with Smart Edoo’s social media, and how you find or may be referred to the Smart Edoo Site. Individual Members may separately use Tracking Technologies within their courses and email communications to understand your activity within a course and how you find or may be referred to a course on the Smart Edoo Site.

Smart Edoo and Members use Cookies and other Tracking Technologies for the following purposes:

·       when necessary for system administration, security, and integrity to ensure the Smart Edoo Site works properly for you. Without these technologies, the Smart Edoo Site may not function correctly;

·       to enable analytics, performance and functionality, to help Smart Edoo and Members gather information about how visitors use the Smart Edoo Site and monitor Smart Edoo Site performance, and to enhance your experience by recognizing and remembering whether you have visited the Smart Edoo Site before and may have any personal preferences; and

·       to support marketing by enabling Smart Edoo and Members to deliver content relevant to your interests on the Smart Edoo Site and third-party sites based on how you interact with Smart Edoo or Member advertisements or content. Smart Edoo and Members use “first-party” cookies, which means cookies served by Smart Edoo or an individual Member, and also “third-party” cookies, which means cookies served by third parties that help Smart Edoo and Members track this information.

You have some options for managing Cookies and other Tracking Technologies. These include:

·       Modifying your browser settings: You should be able to control how and whether your web browser accepts Cookies by adjusting its privacy and security settings. The “help” feature of the menu bar on most browsers will tell you how to stop accepting new Cookies, how to receive notification of new Cookies, and how to disable existing Cookies. If you reject Smart Edoo’s Cookies, many functions and conveniences of the Smart Edoo Site may not work properly.

·       Opting-out of certain third-party tracking and advertising: Some of the third parties used by Smart Edoo or a Member for Cookies and Tracking Technologies offer the ability to opt-out from their tracking by following processes described on their websites. A list of some such third parties is maintained and available at the Smart Edoo learner Help Center and includes, for some, links to applicable opt-out processes. Neither Smart Edoo nor any Member is responsible for the effectiveness of any third-party opt-out options.

HOW YOUR INFORMATION IS USED

Smart Edoo and Members use information, including Personal Information, to carry out the following purposes:

·       Operate and improve the Smart Edoo Site – This includes creating and improving features that support the Smart Edoo community and enable Smart Edoo Site usage at scale. This also includes personalizing the Smart Edoo Site, so your learning experience is tailored to your interests and needs.

·       Create, administer, provide, and teach courses – This includes creating and improving the delivery of massive open online courses and programs on Smart Edoo. This also includes personalizing courses, so your learning experience is tailored to your interests and needs, and assessing your performance and awarding certificates.

·       Offer and improve products and services – This includes enabling you to navigate the Smart Edoo Site, to enroll and participate in courses and programs on the Smart Edoo Site, to learn effectively in such courses and programs, and to purchase or obtain products and services on the Smart Edoo Site such as Verified Certificates.

·       Develop and maintain the security and performance of the Smart Edoo Site – This includes tracking Smart Edoo Site outages and creating software solutions, detecting violations of the Honor Code and Terms of Service, and monitoring uses, misuses, and potential misuses of the Smart Edoo Site.

·       Communicate with you – This includes answering your course and platform questions, notifying you of course and Smart Edoo Site maintenance and updates, marketing to you about course offerings, programs, news, and related products and services of Smart Edoo or Smart Edoo affiliates, and as permitted under applicable law, sending you communications about products or services of selected business partners that may be of interest to you.

·       Support scientific research including, for example, in the areas of cognitive science and education – This includes collaborating to enable and conduct research about how learners access and master course materials online, with the goal of improving course outcomes.

·       Track Smart Edoo Site usage against goals and mission – This includes performing analytics to evaluate access to and performance in courses and course-related products and services and to report aggregate usage information (not Personal Information) to business partners and external audiences.

·       Exercise, enforce, and comply with legal rights and obligations – This includes responding to subpoenas, court orders, or other legal process; and investigating, preventing, or taking action regarding illegal activities, suspected fraud, security or technical issues, or to protect the rights, property, or safety of Smart Edoo, Members, or others, and as otherwise required by applicable law.

Smart Edoo or a Member may also seek your consent for additional uses of information, including Personal Information, and will use it only for the purpose described to you. All use of Personal Information is subject to applicable law.

HOW YOUR INFORMATION IS SHARED

Smart Edoo and Members share information, including Personal Information, with third parties for the following purposes:

·       With service providers, contractors, and other third parties that help carry out the uses described above – Smart Edoo requires third parties to: (1) abide by this Privacy Policy and applicable law; (2) handle Personal Information in a confidential manner and maintain adequate security; and (3) use Personal Information only as needed to fulfill the relevant purpose(s). In some cases, the Smart Edoo Site and individual courses are integrated with third-party services or contain links to websites published by third parties, including other content providers as well as service providers. These third parties are responsible for their own privacy practices, so you should pay attention anytime you are redirected to a third-party website and be sure to review its privacy policy.

·       With other learners in courses that you take and with other visitors to the Smart Edoo Site, to create an interactive learning environment, support class participation, and share course information –This includes sharing comments, coursework, or other information or content that you submit to a portion of the Smart Edoo Site designed for viewing by other class members or for public communication. This also includes providing opportunities for you to communicate with other users who may have similar interests or educational goals, for instance, recommending specific study partners or connecting potential student mentees and mentors. In such cases, Smart Edoo and each Member that offers a course in which you enrolled may use all information collected about you to determine who might be interested in communicating with you, but will only provide others your username (for clarity, no disclosure of your real name or email address).

·       With employers, government programs, institutions, or other enterprises that sponsor your enrollment in a course for training or other educational purposes – If an entity pays for or otherwise sponsors your Verified Certificate or course participation, Smart Edoo will share information with the entity as needed to confirm your enrollment, participation, progress, and completion status in that course.

·       With affiliates of Smart Edoo or a Member, or with successors in the event of a merger, acquisition, or reorganization, for their use consistent with this Privacy Policy.

Smart Edoo or a Member may also seek your consent for additional disclosures of information, including Personal Information, and will share it only as described to you. In addition, Smart Edoo or a Member may share with the public and with third parties, including but not limited to researchers and business partners, information and Personal Information that is de-identified or aggregated in a manner that does not personally identify you.

HOW TO MANAGE YOUR PERSONAL INFORMATION

You can manage your Personal Information through learner features on the Smart Edoo Site and requests to the Smart Edoo learner support team. If your request involves information controlled by a Member, Smart Edoo learner support will notify and coordinate with the appropriate Member to address your request. Smart Edoo will provide support to the extent required by applicable law (for example, learners in the European Union) and more broadly when possible, as a courtesy in our sole discretion. Smart Edoo will notify you in the event that Smart Edoo is unable to meet a request that is not legally required. Similarly, Members will only be obligated to comply with requests to the extent legally required, but may choose to comply with other requests in their sole discretion.

·       Access and correct your Personal Information

Much of your Personal Information is available in your Smart Edoo account. Your name, email address, and other identifiable profile information is editable through the profile settings in your Smart Edoo account except as noted below. Your account dashboard lists all current and archived courses in which you have enrolled and includes links to any Paid Classes you may have earned. The dashboard also contains copies of your answers and other participation and performance in courses. Please contact Smart Edoo learner support to access and update this or other information. If your request involves information controlled by a Member, Smart Edoo learner support will notify the appropriate Member of your request.

Exceptions:

★ Usernames cannot ever be changed. This is an Smart Edoo system restriction. Because usernames identify you in courses and elsewhere on the Smart Edoo Site, Smart Edoo encourages you to use discretion in choosing your username. If you want to protect your identity, do not use your real name or a name identifiable to you as your username.

★ Smart Edoo does not track or index every time or every place on the Smart Edoo Site when or where a learner may volunteer Personal Information, so neither Smart Edoo nor Members will be able to help you locate or manage all such instances. Smart Edoo encourages you to use discretion before volunteering Personal Information on the Smart Edoo Site.

·       Restrict or object to the processing of Personal Information

If you want to manage emails and other communications to you, you may update your preferences in your Smart Edoo account dashboard, follow the steps described in links at the bottom of email messages, or contact Smart Edoo learner support. You may object to, or request that Smart Edoo or a Member stop, its use of your Personal Information for other purposes by contacting the Smart Edoo learner support team. If your request involves information controlled by a Member, Smart Edoo learner support will notify the appropriate Member of your request. Please note that if you choose to restrict Smart Edoo’s or a Member’s ability to process Personal Information, and the processing is otherwise required to provide you with various services and products offered on the Smart Edoo Site, you may not be able to establish an Smart Edoo user account or enroll for a course, and Smart Edoo or a Member may not be able to provide you with those services or products.

·       Delete account and Personal Information

To request deletion of your Smart Edoo account and Personal Information, you should click the button labeled “Delete my account” in your Smart Edoo account settings. Because deletion on the Smart Edoo system is a permanent action and cannot be reversed, Smart Edoo may ask you to complete a process that aims to confirm your authority to manage the Smart Edoo account affected by your request.

With respect to your Smart Edoo account, Smart Edoo will permanently:

·       deactivate your Smart Edoo account,

·       remove the active profile,

·       retire your username, and

·       remove you from Smart Edoo email lists.

With respect to your Personal Information, Smart Edoo will permanently delete your Smart Edoo account profile Personal Information from the Smart Edoo Site.

As noted above, to the extent that Smart Edoo associates the information that Smart Edoo collects directly or indirectly with an individual (for example, you), the association is based on Personal Information in your Smart Edoo account profile. By erasing the Personal Information in your Smart Edoo account profile, the remaining information about your activity on the Smart Edoo Site will no longer be associated with you, except as noted below.

These changes will be applied to data stores that are used for operation of the Smart Edoo Site including course administration by Members. If you enrolled in any courses on the Smart Edoo Site, the Smart Edoo learner support team will share your request with the Members that offered those courses.

Exceptions:

★ Deletion will not apply to historical activity logs or archives unless and until these logs and data naturally “age-off” the Smart Edoo system.

★ Smart Edoo does not track or index every time or every place on the Smart Edoo Site when or where a learner may volunteer Personal Information, so neither Smart Edoo nor Members will be able to help you locate or manage all such instances. Smart Edoo encourages you to use discretion before voluntarily sharing your Personal Information on the Smart Edoo Site.

★ Smart Edoo will archive course data (in a manner and to the extent permitted under applicable law) to serve its mission to enable scientific research on cognitive science and education. These archives are used to produce encrypted research data packages for Members, and Personal Information may not be deleted from research data packages retained by Members.

★ Smart Edoo and each applicable Member cannot always delete records of past interactions and transactions. For example, records relating to previous purchases on the Smart Edoo Site must be retained for financial reporting, audit, and compliance reasons.

★ Smart Edoo and each Member will retain and use Personal Information as necessary to comply with its legal obligations, resolve disputes, enforce its agreements, and as otherwise permitted by applicable law.

·       Data retention

Smart Edoo will retain your Personal Information for as long as your account is active or as needed to provide you with services; to maintain a record of your transactions for financial reporting, audit, and compliance purposes; and to comply with Smart Edoo’s legal obligations, resolve disputes, enforce its agreements, and as otherwise permitted by applicable law. If you enroll in a Member’s course, such Member will also retain your Personal Information for as long as needed to provide you with services; to maintain a record of your transactions for financial reporting, audit, and compliance purposes; and to comply with its legal obligations, resolve disputes, enforce its agreements, and as otherwise permitted by applicable law. Upon your request that Smart Edoo deactivate your account and delete your information, Smart Edoo will follow the process described above, including without limitation archiving your course data (in a manner and to the extent permitted under applicable law) to serve its mission to enable scientific research on cognitive science and education. These archives will be used to produce encrypted research data packages for Members, and each such Member may also keep and use course data for scientific research.

STORAGE & SECURITY

Smart Edoo stores information, including Personal Information, on its own servers and also on servers of companies that Smart Edoo hires to provide services. Each Member also stores information, including Personal Information, on its own servers and/or on servers of companies that the Member hires to provide services. In each case, information may be stored in the United States and in other countries where Smart Edoo or a Member operates, and in countries where Smart Edoo and each Member’s respective service providers operate. If you are in the European Union, Switzerland, or other regions with laws governing data collection and use, you acknowledge that Smart Edoo and each Member may transfer, process and store your personal information in the United States and other countries, the privacy laws of which may be considered less strict than those of your region.

Smart Edoo controls its own copy of information collected through the Smart Edoo Site and has an information security program designed to protect information in its possession or control. This is done through a variety of privacy and security policies, processes, and procedures. Smart Edoo uses administrative, physical, and technical safeguards that reasonably and appropriately protect the confidentiality, integrity, and availability of the information that it collects, receives, stores, or transmits. Nonetheless, no method of transmission over the Internet, or method of electronic storage, is 100% secure; and therefore, Smart Edoo cannot guarantee its absolute security. While Smart Edoo works hard to ensure the integrity and security of its network and systems, Smart Edoo cannot guarantee that its security measures will prevent “hackers” or other unauthorized persons from illegally accessing or obtaining information.

If Smart Edoo learns of a security breach involving its copy of your Personal Information, Smart Edoo may attempt to notify you electronically so that you may take appropriate protective steps. By using the Smart Edoo Site or providing Personal Information to Smart Edoo, you agree that Smart Edoo can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Smart Edoo Site. If a security systems breach occurs, Smart Edoo may post a notice on the Smart Edoo homepage (www.smartedoo.co.ke) or elsewhere on the Smart Edoo Site and may send an email to you at the email address associated with your Smart Edoo account. Depending on where you are located, you may have a legal right to receive notice of a security breach, involving your Personal Information, in writing.

If a Member learns of a security breach involving that Member’s copy of your Personal Information, the Member may attempt to notify you electronically so that you may take appropriate protective steps. By enrolling in a Member’s course on the Smart Edoo Site or providing Personal Information to the Member, you agree that the Member can communicate with you electronically regarding security, privacy, and administrative issues relating to your course enrollment and participation. If a security systems breach occurs, the affected Member may post a notice on the Smart Edoo site and/or send an email to you at the email address associated with your enrollment in the Member’s course on the Smart Edoo Site. Depending on where you are located, you may have a legal right to receive notice of a security breach, involving your Personal Information, in writing.

PRIVACY POLICY UPDATES

This Privacy Policy will be reviewed and updated from time to time. When changes are made, the Privacy Policy will be labeled as “Revised (date),” indicating that you should review the new terms, which will be effective immediately upon posting on this page, with an updated effective date. By accessing the Smart Edoo Site after any changes have been made, you accept the modified Privacy Policy and any changes contained therein. In case you miss the notification referenced above, be sure to return to this page periodically to ensure familiarity with the most current version of this Privacy Policy.

CONTACT INFORMATION

If you have privacy concerns, have disclosed data you would prefer to keep private, or would like to access the Personal Information that Smart Edoo maintains about you, please contact us at [email protected]. You may also write to us at: ATTN: PRIVACY, Smart Edoo Inc., c/o Endpoint Logic Ltd, 31254 University Way, Nairobi, NBO 00600 Kenya. If your request involves a Member, Smart Edoo will notify the appropriate Member of your request.

GLOSSARY

Cookies are unique identifiers usually in the form of small data files placed on your device that send certain information about your activity on the Smart Edoo Site or in an email communication back to Smart Edoo or the authorized third party that served the cookie. Smart Edoo or third parties may also use Flash cookies.

Smart Edoo Site consists of all content and pages located within the smartedoo.co.ke web domain and all Smart Edoo mobile applications.

Member is each educational institution or other leading global institution or entity that provides courses through the Smart Edoo Site.

Personal Information is information that specifically identifies you or that, when combined with other information, could be used to identify you.

Tracking Technologies are web beacons, clear gifs, pixels, and similar technologies that are also unique identifiers used to track your online activity but are not stored on your device.

Verified Certificate is a virtual certificate that shows that you have successfully completed your Smart Edoo course or program and verified your identity using your webcam and your acceptable form of photo ID.

Effective Date: April 01, 2020