Effective Date: September 14, 2022

The Learning Agency LLC (“we”, “us”, or “our”) provides this Privacy Policy (this “Policy”) to inform you about our collection, use, disclosure, and storage of data about you that we collect via our website, competitions, and related offerings and services (collectively, the “Site”). Please review this Policy carefully. By offering your email or name through this Site, or otherwise using the Site or volunteering information to us, you agree to the terms and conditions of this Policy. We may update this Policy from time to time at our discretion, for example to keep up with changing laws regarding data processing. We will always keep the current version of this Policy posted on our website. By using the Site after a new version of this Policy has been posted, you agree to the terms and conditions of that version of this Policy.

DATA WE COLLECT

“Personal Data” means information that can be used to identify you, and may include your name, email address, phone number, mailing address, birthdate, photograph, university, sport, driver’s license, geo-location (if enabled), etc. We collect Personal Data that you voluntarily provide us, for example when you register a user account, sign up for mailing lists or newsletters, enter into a competition, or otherwise reach out to us. Your submission of Personal Data is voluntary, but we may be unable to provide you requested information or services if you choose not to provide necessary Personal Data.

The Site may allow you to create an account or sign in by using a third-party account (e.g., Google, Facebook, etc.). If you choose to use this feature, you acknowledge and agree that the applicable third-party may transfer certain Personal Data to us in connection with such authentication.

“Other Information” means information that does not identify you personally, and may include technical details regarding the device you use to access the Site, IP address, operating system, browser, referral URLs, page views, location data (if location services are enabled), clicks, etc. Our systems automatically collect this kind of Other Information when you interact with the Site. Other Information also includes information that may originally have been Personal Data but has been aggregated or anonymized such that it cannot be used to identify any individual.

COOKIES AND SIMILAR TECHNOLOGY

We use “cookies” to obtain certain types of data when your web browser accesses our website. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser to enable our system to recognize you and your personalized settings, to better understand how you interact with the Site, to monitor aggregate usage, and to optimize web traffic routing on our website. Most browsers have settings to disable or limit cookies, but please note that certain areas or features of the Site may not be available or fully functional if you choose to disable cookies for our websites. We may also use pixel tags, web beacons, session logs, and similar technologies to understand how our users interact with our Site and emails. Our website does not respond to “do not track” signals.

We also use third-party analytics services such as Google Analytics, which help us understand how users are finding and using our Site. Google Analytics collects information such as how often users visit the Site, what pages they visit when they do so, and what other sites they used prior to coming to the Site. We use the information we get from Google Analytics to improve the Site and our offerings and to provide more relevant advertising. To learn more about Google Analytics’ privacy practices, you can visit https://support.google.com/analytics/answer/6004245?hl=en. To opt out of Google Analytics’ metrics, you can follow the instructions at https://tools.google.com/dlpage/gaoptout.

We do not control third parties’ collection or use of your information to serve interest-based advertising. You may be able to opt out of receiving personalized advertisements from companies who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising. For more information about this practice and to understand your options, please visit: http://www.aboutads.info and http://www.networkadvertising.org/choices/. You may also use TRUSTe’s Preference Manager at http://preferences-mgr.truste.com.

USE OF YOUR DATA

We use your Personal Data:

• to verify your identity and eligibility to enter in or participate in competitions, or receive competition prizes;
• to respond to your inquiries and communications to us;
• to improve, maintain, and operate the Site;
• to offer you a more personalized experience on the Site;
• to inform you about competitions, opportunities, events, or services in which you may be interested, including those offered by our affiliates;
• to distribute competition grants awarded to you;
• to investigate and prevent possible fraud;
• to exercise or defend our rights and comply with statutory and regulatory requirements, including responding to lawful requests for information by governmental authorities; and
• in other ways that we identify when we collect the Personal Data or which you have otherwise consented to.

You can opt out of receiving promotional or marketing emails from us at any time by clicking the unsubscribe, opt-out, or similar link at the bottom of any such emails. Please note we may still contact you in connection with your account or any transactions involving you.

We may use Other Information (which does not identify you personally) for any manner we deem appropriate, including without limitation to improve, maintain, and operate the Site.

DISCLOSURE OF YOUR DATA

We will not sell your Personal Data for unaffiliated third-party marketing or solicitation. We may share your Personal Data with our affiliates and as needed to fulfill the purposes described in the “USE OF YOUR DATA” section above, including:

• with staff, judges, and other personnel involved in the administration of competitions that you have entered;
  
• with our service providers, such as customer support providers, anti-fraud specialists, and payment processors, who are only permitted to use the data on our behalf;
• with our affiliates for their internal uses or to facilitate their assisting us in providing services to you or notifying you of products, services, or offers that may be of interest to you;
  
• as necessary to exercise or defend our rights or comply with applicable law or orders from law enforcement and other governmental authorities; and
• to other third parties as disclosed when you provide the Personal Data or which you have otherwise consented to.

Certain competition entrants and winners may be identified publicly on the Site or in press releases or other publicly distributed materials. By entering a competition, you acknowledge and accept that your name and entry or other submission materials may be made publicly available.

Additionally, in the event of a merger, consolidation, sale, or transfer of all or substantially all of our assets or business, one of the assets that would generally be transferred is the data we have collected, which would be transferred subject to the applicable version of this Policy.

We may disclose Other Information (which does not identify you personally) to any parties and for any purposes we deem appropriate.

DATA RETENTION, ACCESS, AND CORRECTION; SECURITY

We are based in the United States, and the Site may be hosted in the United States or other jurisdictions. By using the Site, you consent to your Personal Data being transferred to and stored in the United States or such other jurisdictions.

We may retain your data so long as we can reasonably foresee the data may be required in connection with our business relationship with you. In some cases, we will retain the data for a longer period as necessary to comply with our legal obligations, follow records retention policies, resolve disputes, and enforce our agreements.

You may access and update your Personal Data by visiting your account profile. You may also request erasure of your Personal Data in certain circumstances. To request access to, correction of, or erasure of your Personal Data, please contact us as set forth at the end of this Policy.

We understand the importance of preserving the security of your Personal Data. Accordingly, we use industry-standard administrative, physical, and technological measures designed to protect your Personal Data from unauthorized access or use. However, no internet transmission can be guaranteed to be 100% secure from interception or other unauthorized access. Please do not provide any sensitive Personal Data (like credit card number or social security number) through unprotected methods like email correspondence.

YOUR CALIFORNIA PRIVACY RIGHTS

California law entitles California residents to certain additional protections regarding Personal Data. For purposes of this section alone, “Personal Data” means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. California residents have the right to request:

• information regarding your Personal Data we have collected in the past 12 months (including the categories of Personal Data we have collected, the categories of sources of such information, and the purposes for which we have collected such information);
• notice of whether we have disclosed your Personal Data to third parties in the past 12 months (and if so, what categories of information we have disclosed, and what categories of third parties we have disclosed it to);
• a copy of your Personal Data collected by us in the past 12 months; and
• that your Personal Data be deleted.

We will not discriminate against you if you choose to exercise any of these rights. To make any of the above requests, please contact us as set forth at the end of this policy. We may require verification of your identity before further processing your request. In certain instances, we may be permitted by law to decline some or all of such requests.

CHILDREN

Our Site is not intended for users under 13 years of age, and we do not knowingly collect Personal Data from users under 13. If you are under 13, do not provide any information on or through the Site. If we learn we have collected or received Personal Data from a child under 13 without verification of parental consent, we will take commercially reasonable steps to promptly delete that information. If you believe that we might have any Personal Data from or about a child under 13, please contact us as set forth below.

THIRD PARTY SITES

The Site may include hyperlinks or other references to third-party sites and services. If you visit or use such third-party sites and services (or third-party functionality such as payment processing services), please be mindful that the relevant third party (not us) controls the cookies and other technologies it uses on its sites and how it collects, uses, and shares Personal Data from you. This Policy only governs our own privacy practices; please review the applicable third-party privacy policy when visiting or using any third-party sites or services. We may receive compensation from such third parties.

CONTACT

For more information or for help in answering any questions, please contact us.