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Privacy Policy

EDforTech Corp. Privacy Policy

Effective Date: January 31, 2020 

Last Updated: October 1, 2022 

PRIVACY POLICY AND CHILDREN’S PRIVACY POLICY 

This Privacy Policy explains what information will be collected by EDforTech Corp (“EFT”, “we,” “us,” or “our”) when you access our websites, software, applications, connected products or related services (collectively, the “Service”) and how the information will be used. 

We do not collect data to share with others. We will not use or share your information with anyone except as described in this Privacy Policy. Each time you use our Service you are accepting the practices described in this Privacy Policy, as applicable, at that time. 

OVERVIEW 

Most of the websites operated by EFT are websites intended for grown-ups (parents, educators, developers, etc.) to learn about and/or purchase our products and services. These websites (which we refer to as our “General-Audience Sites”) include, but are not limited to, our main website EDforTech.com, our e-commerce site at exploringrobotics.com and our teachers’ and student course sites at RobotCourse.com and Ed4Tech.com. We do not knowingly solicit or collect Personal Information (defined below) from children under the age of 13 (“Children Users”) on these General-Audience Sites. 

The robots sold on our website developed by other Manufacturers and Software Developers and their corresponding mobile applications, (together, our “Child-Directed Products”) are generally intended to be used and enjoyed by children, students, and teenagers of all ages. The Apps for these robots are provided by their manufacturers who employ special measures when collecting or processing information through their Child-Directed Products and generally avoid or limit the collection of Personal Information through these products. For more details on our practices related to children, please see the section on Children’s Privacy below. 

Definitions 

This Privacy Policy uses certain capitalized terms that have particular meanings. Sometimes, those terms are defined when they are first used. In addition, and for ease of reference, the following terms are defined in this section: 

· “App” means any software application, including, but not limited to, Android and/or iPad and/or iPhone software applications provided by EFT or any software application that EFT resells from a manufacturer or software development company. 

· “Browsing Information” means information about your use of the Service, or your computer’s (or other access device, such as an iPad or smartphone) interaction with the Service. Browsing Information also includes certain of the information described in the “Information Collected Automatically” section below. This information is linked to a device identifier, such as the Internet Protocol (IP) address of your computer or device. Some robots include a product identifier, and through the App your robot transmits information to the manufacturer that they may use to provide services, assist you in troubleshooting, and improve the products, services, Website and App. In general, EFT does not use Browsing Information to identify you, but such information may be paired with Personal Information, or with other information that together, could be used to identify you. Additionally, third parties, such as analytics companies and advertising service providers may access, collect, store, and use Browsing Information, and they may use it to identify you. 

· “Personal Information” means information that directly identifies you, or that can directly identify you, such as your full name, physical address (home, mailing, shipping, and/or billing address), e-mail address, phone number, and/or credit card information. In the case of Children Users, Personal Information may also include the child’s precise geo-location, school name/address, a photo, video, or audio file that contains the child’s image or voice, and/or a persistent identifier (such as an IP Address or device ID) when such information is not used for internal support purposes. 

· “Product Use Information” means information related to use of one of our products, such as robot name, activities coded, or similar information. Product Use Information is linked to the product identification number of your robot. 

· “User Content” means any content that you personally create or produce and upload to our Service, such as a comment, message, photo, video, voice recording, artwork, software code or program, or other similar content. User Content may (in some cases) contain Personal Information if Personal Information is provided within the User Content. 

· “Website” or “Site” means any websites, web pages, and any subpages (including mobile websites, web pages and subpages) under EFT’s control, whether partial or otherwise. This includes but is not necessarily limited to the General-Audience Sites listed above, and any subpages of these websites. 

INFORMATION WE COLLECT 

Personal Information We Affirmatively Collect From You 

We may collect Personal Information from you, such as first and last name, phone number, email address, physical address, school information, and/or credit card information, when you: (i) register for an account on our Service, (ii) sign up for our newsletter, (iii) make a purchase or order on our General-Audience Sites, (iv) include Personal Information in User Content that you upload to our Service, or (v) set up or enable certain features for your child/student on the Child-Directed Products we resell. Other profile information you may affirmatively provide to us about you or a child or student (such as birthdate, age, gender, username, password, etc.) may be collected and maintained together with your Personal Information. You can choose not to provide any information that is requested of you by us. However, this may limit your ability to use or access the Service. 

Additionally, if a friend refers you to us by providing us with your e-mail address, we may send you a message. However, we will use your e-mail address only to send the friend’s message unless you otherwise affirmatively provide information to us. 

In addition to collecting information on the Service, we may collect information from you when you communicate with us over the phone, including via text messages or via e-mail. This information may include Personal Information. This information may be matched with, and stored in connection with Personal Information provided or collected in connection with your registration for or use of the Service. 

We also may now or in the future receive Personal Information about you from third parties. For example, if you access our Service or Site through a third-party connection or log-in, including social networking services such as Facebook where you have a registered account, that third party may pass certain information about your use of its service to EFT. This information could include, but is not limited to, the user ID associated with your account, an access token necessary to access that service, any information that you have permitted the third party to share with us, and any information you have made public in connection with that service. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to the EFT Service or Site. 

Please note that the third party functionalities described above are not made available to Children Users. For more details on our data collection practices for Children Users, please see the section on Children’s Privacy below. 

Information Collected Automatically 

Log file information is automatically reported by your browser each time you access a web page on our Service. When you access the Service, our servers automatically record certain information that your web browser sends whenever you visit any website. These server logs may include information such as your IP Address, web request, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other similar information. 

Product Use Information is also automatically transmitted to us (or the product manufacturer) through Apps and used to provide product support, improve our products and services, and for similar activities that support our internal operations. If you share your robot with someone or resell your robot to someone else, your Product Use Information that is stored and has been transmitted to us by your robot will remain in the possession of the manufacturer. In addition, any User Content (such as altered voice recordings) that you create and store on your robot can potentially be played back by the new owner of your robot, unless you remove such recordings in advance. For guidance on how to remove such recordings, please contact EFT using the contact information at the bottom of this Privacy Policy. 

We may use certain third party services including, but not limited to, Google Analytics, to help us understand your use of the Service. These services collect information about your use of and the performance of the App, the Site, and/or robots and also collect information sent by your browser as part of a web page request, including cookies and your IP Address. In general, we will store tracking information in an anonymous aggregated form, however, we or our third party tracking partners may store certain information, such as pageviews, in a manner that can be associated to specific devices. 

We use persistent cookies and session cookies. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the Service. Persistent cookies can be removed by following your web browser’s directions, but such removal may affect your use of or access to certain portion of the Service. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. If you refuse cookies you may not be able to experience all the features of our Service. 

Third Party Ad Networks 

For our General-Audience Sites, EFT may partner with third party advertisers, ad servers, and ad networks that use cookies, beacons, tags, scripts and other tracking technologies (“Third Party Advertising Companies”). These companies may use information about your visits to our General-Audience Sites and other websites in order to provide advertisements about goods and services of interest to you, including re-targeted ads that attempt to direct you back to our General-Audience Sites or ads targeted based on your overall browsing interests. If you do not wish to receive such targeted ads, please visit the websites below to learn about how you may opt out of receiving targeted ads and enable opt-out settings. 

· https://optout.aboutads.info/

· https://optout.networkadvertising.org/

On our Child-Directed Products, EFT does not show behaviorally-targeted or retargeted ads to Children Users or track Children Users for targeted advertising purposes. 

Some web browsers may automatically transmit “do-not-track” signals to the websites which users visit. EFT does not currently process or respond to such automated “do not track” signals or other transmissions that indicate a request to automatically disable online tracking of users who visit or use our Service. 

HOW WE USE YOUR INFORMATION 

We use or may use Personal Information and Browsing Information for a variety of purposes, including: 

· To operate the Service, monitor the effectiveness of the Service, to improve the content of the Service, and layout and design. 

· To help provide you with a smooth, efficient user experience. 

· For billing, identification and authentication, and fraud prevention. 

· To respond to any inquiries or requests received from you. 

· To monitor, analyze and describe usage patterns and performance of the Service, including aggregate metrics such as total number of visitors, traffic, and demographic patterns. · To contact you and deliver administrative notices and communications relevant to your use of the Service, such as security or support and maintenance advisories. · To conduct system administration and system troubleshooting and to diagnose or fix technology problems. 

· To comply with legal requirements and process (for example, in response to subpoenas, court orders, and law enforcement or governmental requests or investigations), to protect our legal rights or the rights of others (for example, by working to reduce the risk of fraud or misuse of the Service). 

· To enforce our Terms of Use or other policies or agreements. 

· To send promotional communications and/or newsletters to you and for other marketing purposes of EFT or partners. 

· In connection with an unusual business transaction, such as the bankruptcy or liquidation of, sale of, purchase of, or merger with our business or another business. · For distribution to third-party service providers that provide services to EFT and partners of EFT. 

· As otherwise set forth in this Privacy Policy. 

HOW WE SHARE YOUR INFORMATION 

Personal Information: Except as set forth below, EFT will not rent or sell your Personal Information to others, or share it with independent third parties for their separate marketing-related purposes. To operate the Service, however, we may share your Personal Information with our agents, representatives and contractors so they can provide us with support services and other features and fulfill your orders. We require these third parties not to use your Personal Information for any other purpose. We may store Personal Information in locations outside the direct control of EFT (for instance, on servers or databases co-located with hosting providers). 

Browsing Information: We may share non-personally identifiable information (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with interested third parties to help them understand the usage patterns for our Service. Non-personally identifiable information may be stored indefinitely. 

Instances where we are required to share your information: EFT will disclose your information where required to do so by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Use or to protect the security or integrity of our Service and our property (including our intellectual property); and/or (c) to exercise or protect the rights, property, or personal safety of EFT, our users or others. 

What happens in the event of a change of control: We may buy or sell/divest/transfer our company (including any shares in our company), or any combination of our products, services, assets and/or businesses at any time. All information, whether Personal Information or Browsing Information, related to the Service may be sold or otherwise transferred in connection with any such transaction(s). We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the company. Any transferees who receive your information in connection with a change of control must abide by the terms of this Privacy Policy. 

STORAGE AND PROCESSING 

Your information collected through the Service may be stored and processed in the United States or any other country in which EFT or its subsidiaries or service providers maintain facilities. EFT may transfer information that we collect about you, including Personal Information, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including Personal Information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. or any other country in which EFT or its parent, subsidiaries, or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy. However, such parties must abide by the terms of this Privacy Policy. 

YOUR CHOICES ABOUT RECEIVING MARKETING MESSAGES 

EFT offers parents, teachers, and other adults the choice of receiving different types of communication and information related to our company, products and services. You may subscribe to e-newsletters or other publications or you may also elect to receive marketing communications and other special offers from us via email. To help us understand whether we are providing information of interest to you, we may include software code or other tracking technologies in our emails to monitor whether you opened a particular email, whether you have clicked on the images and/or links in the email, the date and time the message was opened, and whether your computer is capable of receiving HTML-based email. We endeavor to allow you to unsubscribe at any time from our email programs by clicking on the unsubscribe link at the bottom of any email message. You may also access and manage your preferences from your account, when available, or by contacting us directly at the contact information below. We reserve the right to send you service announcements or similar administrative messages, without offering you the opportunity to opt out of receiving them. 

HOW WE PROTECT YOUR INFORMATION; SECURITY AND PASSWORDS EFT takes what it believes to be commercially reasonable physical, electronic, and procedural safeguards to protect Personal Information. However, since no security system is impenetrable and “perfect security” does not exist on the Internet, we cannot guarantee the security of Personal Information or Browsing Information. 

If you create an account to use the Service, you may be asked to choose a password for your account, which can be used to access information associated with your account (including Personal Information). You should choose a password that is not easy to guess, and does not use words that you would find in a dictionary. Do not disclose your password to any other person. You are responsible for maintaining the confidentiality of your password and account, and we will attribute activities that occur using your account information (e.g., through the use of your password) to you. If you suspect that your password has been compromised contact us immediately at using the contact information below. 

HOW YOU CAN UPDATE YOUR INFORMATION 

EFT believes strongly in giving you the ability to access and update or correct your Personal Information. You may update your Personal Information by logging into your account on EFT’s Website, when available, or by contacting us directly using the contact information below. 

CHILDREN’S PRIVACY 

We care about children’s privacy and are committed to complying with the Children’s Online Privacy Protection Act (COPPA). To learn more about COPPA, please consult this simple one-page informational guide from the kidSAFE Seal Program: https://www.kidsafeseal.com/knowaboutcoppa.html

Please note that while the Child-Focused Products offered by us (or by the Manufacturers and Developers whose products we resell) are aimed to be usable by children, students, and young teenagers, that only parents, legal guardians, educators or school administrators, or other adults are allowed to make purchases on our General-Audience Sites or within the Child-Focused Products. 

To set up your robot, a parent or guardian or educator if part of an education class (aka Adult) should download the corresponding App and assist with account creation (if applicable). As part of the account creation, we may ask a Adult to provide an email address, account password, and limited profile information (username, birthdate, gender, etc.) about the child using the robot. This information is used to customize the robot experience for the child and to keep the Adult informed of the child’s activities. 

In compliance with COPPA, the parent’s email address may be used to notify and obtain verifiable consent from a parent before activating an account or enabling certain data collecting features for their child (such as chat messaging between the child and robot). The parent account information may also be used for account management purposes (e.g., profile updates, password reset, login for another EFT Website, etc.) and to communicate with the parent about new products, features, newsletters, and special promotions and events. Product Use Information is used only to support our internal operations. 

In some instances, EFT may collect a limited amount of personal information from a parent or child (such as an email address) and use such information for a one-time event or communication (e.g., one-time contest, share your code submission, etc.) or for multiple ongoing communications to a child (e.g., email alerts, push notifications). For these types of activities, EFT may rely on exceptions to the parental consent requirement under COPPA or follow other procedures to ensure compliance (e.g., removal of personal information prior to collection or immediately after use, parental notification with opt-out mechanism, local storage of the information with no uploading to the web, etc.). 

EFT does not currently offer any features on our Child-Directed Products that would allow Children Users to publicly post or share Personal Information with other users via the web. Some features on our Child-Directed Products may allow the storage of information (including Personal Information) locally on an App or robot device, without the uploading of such information to the web or EFT servers. Parents are still advised to remove any such information from their robot device, should they choose to sell, donate, or gift their device to someone else. 

On our Child-Directed Products, we may collect and process Product Use Information and Browsing Information from Children Users, but only for purposes of supporting our internal operations, such as to help us: 

· Maintain or analyze the functioning of our Child-Directed Products; · Perform network communications; and 

· Authenticate users of, or personalize the content on, our Child-Directed Products. On our Child-Directed Products, we do not use Product Use Information or Browsing Information for behavioral or re-targeted advertising purposes or to allow third parties to track the activity of Children Users for such purposes. 

With proper authentication, a parent or legal guardian always has the right to review the Personal Information we may have collected and stored about their child, request deletion of such Personal Information, or refuse to allow further collection or use of such information by EFT. Please keep in mind that a request to delete such information may limit the child’s access to all or a portion of the Service. If you believe that a child under 13 might have provided us with Personal Information without your permission, or if you wish to view, request deletion of, or prohibit further collection of information about your child, please contact us using the contact information below. We urge parents to monitor their children’s use of all digital media. 

STUDENT PRIVACY AND PROTECTION 

We recognize the importance of protecting the privacy and safety of students who use our services. Our commitment to student data privacy is demonstrated through stringent protective measures, adherence to industry best practices, and compliance with applicable laws and regulations concerning student data. Below, we detail our dedicated approach to ensuring the privacy and security of student information. 

Robust Data Security 

Industry-Standard Measures: We employ comprehensive, industry-standard security measures to protect student data against unauthorized access, disclosure, alteration, and destruction. This includes the use of encryption, secure socket layer (SSL) technology, and robust firewall protections. 

Access Controls: Strict access controls are in place to ensure that only authorized personnel have access to student data, and only for legitimate educational or operational purposes. Employees are trained on the importance of data privacy and the need to maintain the confidentiality and security of the information. 

Regular Security Audits: We conduct regular security audits and assessments to identify and remediate potential vulnerabilities in our systems and to ensure the ongoing security and integrity of student data. 

Data Retention and Deletion 

Clear Retention Policies: Our data retention policies are clearly defined and communicated. We ensure that student data is retained only for as long as it serves authorized educational purposes or as required by law. 

Secure Deletion Practices: Once the retention period expires, or when the data is no longer needed for the purposes for which it was collected, we securely delete or anonymize the student data in accordance with our data deletion policies and applicable regulatory requirements. Incident Response 

Proactive Incident Management: We have established a comprehensive incident response plan to promptly and effectively respond to any data breaches or security incidents. This plan includes procedures for containment, eradication, and recovery to minimize any impact of a security incident. 

Notification Procedures: In the case of a data breach or security incident, we are committed to swiftly notifying the relevant stakeholders, including students, parents, and regulatory authorities, as required by law, ensuring transparency and accountability. Parental Consent 

Compliance with Laws: We adhere strictly to all applicable laws and regulations regarding student data, including the requirement for parental consent when necessary. Our practices are designed to ensure that parents are fully informed and provided with control over their children’s personal information. 

Engaging Parents: We engage parents in our privacy practices, providing clear information about the data we collect, how it is used, and the controls available to them. We respect parents’ rights to access, review, and request the deletion of their child’s data. 

LINKS TO OTHER WEB SITES 

We are not responsible for the practices employed by websites or services linked to or from the Service, including the information or content contained therein. Please remember that when you use a link to go from the Service to another website, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link or advertisement on our Website, are subject to that third party’s own rules and policies. We encourage our users to be to familiarize themselves with the privacy statements of all websites and apps that they visit and interact with. 

CALIFORNIA PRIVACY RIGHTS 

Users who are California residents may request and obtain from us once a year, free of charge, certain information about the Personal Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of Personal Information that was shared and the names and addresses of all third parties with whom we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing using the contact information below. 

VISITORS RESIDING OUTSIDE THE UNITED STATES 

EFT and its Service are based in the U.S., and EFT’s offices are headquartered in the U.S. Please be aware that information you provide to EFT or that it obtains as a result of your use of the Service may be processed and transferred to the U.S. and be subject to U.S. law. The privacy and data protection laws in the U.S. may not be equivalent to such laws in your country of residence. By using the EFT Website or Child-Directed Products, participating in any of the Service, or otherwise providing EFT with your information, you (or a parent/guardian on your behalf) consent to this collection, transfer, storage, and processing of information to and in the U.S. EFT will take commercially reasonable steps to safeguard your data in accordance with this Privacy Policy, but is not responsible for the privacy and security practices of third parties. 

UPDATES TO OUR PRIVACY POLICY 

We reserve the right to update this Privacy Policy from time to time. When we do, we will post them here and revise the “Effective Date” at the top of this Privacy Policy. We encourage you to check this page periodically for any updates. If you continue to use the Service following the posting of an updated version of this Privacy Policy, we will treat your continued use as acceptance of the updated version. 

If we make a material change in the way we handle previously collected Personal Information of our users, we will notify you more prominently and obtain your prior consent or the prior consent of a parent or legal guardian, as applicable and legally required. 

CONTACTING US 

If you have any remaining questions about how we treat your privacy, just let us know. You can contact us by writing to us at support@exploringrobotics.com or Privacy Manager, EDforTech Corp, 555 Conger St, Eugene OR 97402. Phone:1-760-650-2687 

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