3C Institute for Social Development, Inc. and its affiliates (“3C”) believe the protection and privacy of your Personal Data and Non-Personal Data (collectively “Data” or “Your Data”) is paramount and we value your right to privacy. 3C strives to protect Data we collect through your interaction with the 3C web sites, products, services, games, content, databases, software, and other technologies (collectively, “Services”). Our goal is to keep Your Data secure and 3C only uses Your Data subject to this Privacy Policy.

3C is committed to working with you to obtain a fair and rapid resolution of any queries, complaints, or disputes about privacy. If you have any questions or comments about our Privacy Policy, please contact support@3cisd.com or 1-984-316-0406.

This Privacy Policy is available on the 3C website at https://www.3cisd.com/.

1. Data 3C Collects

You may provide us information when you register for the Services, access or use Service content or features, sign up to receive emails or other communications, use community features such as discussion forums, participate in promotions, or directly contact us with questions or feedback. 3C may also collect Data as described below:

a. Personal Data 

“Personal Data” is Data you provide to us, or we may otherwise collect, that identifies you directly. This also includes information associated with you that could potentially identify you, including when combined with other information from or about you. We will not collect or use Personal Data except as stated in this Privacy Policy. Personal Data includes Data:

• Entered by you during registration or account set-up – To access and use some Services, an account is required. With that account, we collect username, password, and email address as well as other personal data needed to set up and optimize that Service. Other Personal Data may include, among other things, name, address, telephone number, age, gender, language, grade level, birth date, payment, billing (including credit card), and shipping information.
• Entered by you during interaction with a Service – Some Services collect personal or performance data via surveys, forms, tests, and other tasks where users complete activities during the course of learning, practicing, and/or demonstrating knowledge or skills targeted by that Service. We store your survey/form/application data and provide analysis tools to you and applicable third parties (such as parents, educators, or other qualified entities) for use with respect to this data, as appropriate for the given Service. You may also provide information, comments, and correspondence in interactive online forums and other collaboration features of the Services. When users (including children) interact with a Service, their actions and choices made during the course of completing a training, assessment, or other online activity may be automatically collected. This information may be collected using proprietary software scoring algorithms and code.
• Entered by an authorized third party – We may collect your Personal Data from a third party (e.g., educator, researcher, agency) if you give permission to those third parties to share your information with us. Third parties are able to login to a separate administrative account and enter data on behalf of other users. If any such third parties exist for a given Service, these individuals and/or entities are listed on that Service.

b. Non-Personal Data 

“Non-Personal Data” can be technical information or it can be demographic information, such as your ZIP code, other geolocation data or interests. Non-Personal Data can include information automatically collected through the use of cookies. Non-Personal Data does not identify you personally but may be tied together with other data to identify you. Aggregate or summary data across users is considered Non-Personal Data. Here are some examples of Non-Personal Data that is collected via Services and a description of how this information is used:

• Device Data — Device data includes your Internet Protocol (IP) address, operating system version, device type, system and performance information, and browser type. Your IP address is a number that lets computers attached to the Internet know where to send you data — such as the web pages you view. If you are on a mobile device, we also collect the universally unique identifier (UUID) for that device. We use this information to deliver our Services to you upon request, to tailor Services to the interests of our users, and to measure traffic on our Services.
• Usage Data – We use third party tracking services (Google Analytics) that employ cookies and page tags to collect data about visitors to our websites. This data includes usage and user statistics (such as webpages you visit, what you click on, when actions were taken, language preferences, etc.).
• Referral information – If you arrive at a Service from an external source (such as a link on another website or in an email), we record information about the source that referred you to us.

2. Cookies

Cookies are text files sent by Web servers to Web browsers and are stored on the user’s computer or mobile device. If the browser is loading a page and the server requests the data stored in the cookie, the data contained within the cookie is sent back to the server. Cookies contain data about the user’s activities on a website and can be used by Web servers to identify and track users as they navigate different pages on that website and can identify users returning to that website.

Cookies may be either “persistent” or “session” cookies. 3C uses persistent cookies to enable our Services to recognize you when you visit or return to a Service. This Data includes the browser or operating system that you use, your IP address, and the date and time you have viewed certain pages on Services, by ways of example. Persistent cookies will remain stored on your computer until you delete them or until they expire automatically at their expiration date. Session cookies are temporary cookies that typically expire at the end of the web browsing session on a website. 3C uses session cookies to keep track of you while you navigate a Service. A session cookie expires at the end of the user session, i.e., when the Web browser is closed.

By using Services, you are consenting to our use of cookies in accordance with the terms of this Privacy Policy.

a. How 3C Uses Cookies

Cookies contain Data that we have previously stored from prior interactions with a Service and may allow us to link to other Data we have about you (such as previous purchases and subscriptions). Services use Data we obtain from cookies for the following purposes:

• To recognize the user’s computer when the user visits the website;
• To track some user actions only during the current website session;
• To improve the Services’ usability;
• To analyze the use of the Services;*
• To assist 3C with administering the Services; and
• To share Data for Services with applicable third parties.

*We use Google Analytics to analyze the use of Services. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The Data generated is used to create reports about the use of the website. Google stores this Data. More information is available at Google’s privacy policy at https://policies.google.com/privacy?hl=en&gl=us.

b. Third-party Cookies

When users visit Services, third-party cookies (such as Google advertising cookies) may be sent to their computers by 3C’s service providers. Third party advertisers may use data obtained from these cookies:

• To track users browsing across multiple websites;
• To build profiles of users’ Web surfing; and/or
• To target advertisements that may be of particular interest to users.

c. Managing Your Cookie Settings

Most browsers allow you to control cookies through their settings preferences. However, if you limit the ability of websites to set cookies, you may limit your overall user experience, since it will no longer be personalized to you. It may also stop you from saving customized settings like login information.

3. How 3C Uses Your Data

Except as described in this Privacy Policy, we do not use, sell, transfer, or otherwise disclose to third parties any Personal Data that we collect directly from or about you. 3C uses Personal Data that is collected on Services in the following ways:

• To deliver Services you request or purchase;
• To process your order and, if necessary, contact you regarding the status of your order;
• To fulfill the terms of a promotion or discount;
• To allow you access to restricted areas of Services;
• To provide technical assistance and support for use of the Services, as needed;
• To provide information on the use of Services to authorized third parties who oversee or administer use of a given Service by users (such as agency-level administrators, supervisors of providers, continuing education providers)—if any such third parties exist for a given Service, these individuals and/or entities are listed on that Service. This data may be used to inform parents, guardians, educators, and other qualified entities about the user’s performance and progress in the Service;
• To request your feedback about your experience to ensure the Services are relevant to your needs;
• To improve usability, accessibility, and effectiveness of our Services;
• To notify you about a material change to this Privacy Policy or 3C’s Terms of Use, if necessary;
• To help us create and update content on Services to be most relevant to you;
• To alert you to special offers, updated information, and other news from 3C, related third parties, or to forward promotional materials; and
• For other business purposes that help optimize your experience as you interact with Services.

4. Google Analytics Advertising Features 3C Has Implemented

3C may use certain Google Analytics Advertising Features, which contain third party cookies. Google Analytics is a web analytics tool that helps website owners understand how visitors engage with their website. 3C follows the Google Analytics policy requirements found at https://support.google.com, which are incorporated herein by reference. The specific Google Analytics Advertising Features that 3C uses include only the following: Google Display Network Impression Reporting, Google Analytics Demographics and Interest Reporting, and Integrated Services that require google analytics to collect data via advertising cookies and identifiers. 3C does not use the Google remarketing features. You can opt out of the foregoing Google Analytics Advertising Features by following the instructions at this link: https://tools.google.com/dlpage/gaoptout/.

5. Release of Data to Third Parties

Personal Data collected as a function of the Services will not be released to third parties except to further the purpose for which you provided the Data and in the following instances:

• To fulfill a Service to you including answering questions, completing an order, or providing technical assistance;
• To an authorized third party identified as the copyright holder of a particular Service. In the instance a Service is owned by a third party, that third party will be listed in the website footer next to the © symbol on the login page for that Service.
• To an authorized third party as identified on the Service as having permission to access, view, enter, and/or use your Personal Data (such as a supervisor, employer, administrator, parent, or other qualified individual or entity);
• To unaffiliated service providers, agents, or independent contractors who help us maintain our Sites and provide other administrative services to us (including, but not limited to, order processing and fulfillment, providing customer service, maintaining and analyzing data, sending customer communications on 3C’s behalf). We seek to ensure that these unaffiliated third parties will not use the
• Personal Data for any other purpose than to provide the administrative services for which they are responsible;
• To complete your purchase if you choose to make a purchase of or through the Services. We will collect from you your credit card number, billing address, and other Data related to such purchase, and we use such collected Data to fulfill your purchase. We may also provide such Data to unaffiliated third parties as necessary to complete your purchase (for example, to process your credit card);
• To comply with the law or in the good faith belief that such action is necessary to conform to the requirements of law or comply with legal process served on us, protect and defend our rights or property, including the rights and property of 3C and Services, or act in urgent circumstances to protect the personal safety of our end users;
• To third parties as part of any corporate reorganization process including, but not limited to, mergers, acquisitions, and sales of all or substantially all of our assets; and
• To protect against potential fraud, we may verify with third parties the Data collected from Services. In the course of such verification, we may receive Personal Data about you from such services. In particular, if you use a credit card or debit card to purchase services with us, we may use card authorization and fraud screening services to verify that your card Data and address matches the Data that you supplied to us, and that the card has not been reported as lost or stolen.

All third parties function as our agents, performing services at our instruction and on our behalf pursuant to contracts which require they provide at least the same level of privacy protection as is required by this Privacy Policy and implemented by 3C.

With regard to the principle of Accountability for Onward Transfer, for example, we remain liable if our agent processes such personal information in a manner inconsistent with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage.

6. Third Party Websites and Advertisers

Some Services may provide you with links to other websites and services. In the event you choose to access such websites or services, 3C is not responsible for any actions or policies of those sites or services. Further, please note that the third party’s Privacy Policy, Cookie Policy, or security practices may differ from 3C’s. 3C neither assumes responsibility for, nor does it control, endorse, or guarantee any aspect of your use of the linked site or service. We recommend that you check the Privacy Policy, Cookie Policy, and other pertinent security practices of such a party before providing Personal Data to it.

3C may also permit advertisers, third party ad networks, or other advertising companies to place advertisements on Services. Please be advised that such companies may gather Data about your visit to Services (through cookies, web beacons, and other technologies) to enable such advertising companies to market products or services to you, to monitor which ads have been served to your browser and which Web pages you were viewing when such ads were delivered. Follow this link to learn more: http://optout.networkadvertising.org/?c=1#!/

PLEASE NOTE THAT THIS POLICY DOES NOT COVER THE COLLECTION AND USE OF DATA BY SUCH ADVERTISING COMPANIES.

7. Forums, Chat Rooms, and Other Public Posting Areas

Please note that any Data you include in a message you post to any forum, discussion boards, chat rooms, or other public posting area is available to others. If you don’t want people to know your email address, for example, don’t include it in any message you post publicly. PLEASE BE EXTREMELY CAREFUL WHEN DISCLOSING ANY DATA IN CHAT ROOMS, FORUMS, AND OTHER PUBLIC POSTING AREAS. WE ARE NOT RESPONSIBLE FOR THE USE BY OTHERS OF THE DATA THAT YOU DISCLOSE IN PUBLIC POSTING AREAS.

8. Opt Out of Communications

We communicate with users on a regular basis via email. For example, we will use your email address to contact you to confirm a request you have made of 3C, to send you notice of upcoming payments that are due, to send you information about changes to our Services, to send notices and other disclosures as required by law, and to send you a periodic 3C newsletter or other communications. 3C provides you the opportunity to opt out if you do not want to receive communications from us regarding new Services offered by 3C or if you do not want us to share your Personal Data with third parties for non-Service related purposes. For emails, you may opt out by clicking on the “unsubscribe” link within the text of an email. We will process your request to unsubscribe as soon as possible, but please be aware that in some circumstances you may receive a few more messages until the unsubscribe request is processed. If you have elected to receive notices to your mobile device via text message, you may opt out by replying “STOP” to such mobile messages. You may receive a confirmatory text message in response to your “STOP” request and you hereby consent to receipt of such confirmation. As noted above, to opt out of the Google Analytics advertising features outlined above, follow the instructions at this link: https://tools.google.com/dlpage/gaoptout.

9. Data Retention

We keep your Data for as long as your relationship with Services continues and as required by law. We retain your Data as necessary to continue to provide Services including fulfilling orders, accessing applications, etc. This includes Data you or others provided to us and Data obtained from your use of Services. There may be some instances where we retain Non-Personal Data in a depersonalized or aggregated form.

10. Rights to Access and Control Your Personal Data

We provide you with several options for managing Your Data, including:

• Delete Data: You can ask us to erase or delete all or some of Your Data and we will work hard to honor all requests in a timely manner. In some instances we may not be able to delete your Personal Data in order to comply with applicable laws (for example, it is necessary to keep the financial records of a transaction with you). You can request that 3C delete Your Data by emailing us at support@3cisd.com or calling 1-984-316-0406.
• Change or Correct Data: We offer settings to control and manage Your Data through your personal login account. You can edit some of Your Data through functions available once logged into your personal account. You can also ask us to change, update, or fix your data in certain cases, particularly if it’s inaccurate.
• Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of Your Data.
• Right to Access and/or Take Your Data: You have the right to see Your Data and take Your Data and we will work with you to be sure we can provide the most complete set of Your Data and a secure way to transfer Your Data.
• Resignation/Account Closure: You may ask us to close your account. We will keep some of Your Data even after you close your account in order to fulfill any final Service requests and if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms of Use, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized Data after your account has been closed.

Your Data may continue to be accessed by others until they refresh their cache. We will not delete any comments or posts you have made on any public posting areas.

11. Your California Privacy Rights

California Civil Code Section 1798.83 permits our visitors who are California residents to request certain information regarding 3C’s disclosure of personal data to third parties for their direct marketing purposes. To make such a request, please contact us at support@3cisd.com or 1-984-316-0406.

12. Children’s Privacy

Some of our Services are intended for and are used by children. “Children” are individuals under the age of 13 (or under a higher age if mandated by the laws of the jurisdiction in which they reside). 3C is committed to protecting the privacy of children who use our Services. 3C complies with the Children’s Online Privacy Protection Act (COPPA), which imposes certain requirements on operators of websites or online services directed to children under 13 and on operators of other websites or online services that have actual knowledge that they are collecting personal information online from children under 13. 3C practices are compliant with the guidelines provided by the Federal Trade Commission to date. Specifically:

• 3C Institute will never knowingly request personally identifiable information from anyone under the age of 13 without parental or educator consent.
• 3C Institute does not share personally identifiable information from anyone under the age of 18 without prior parental or educator consent.
• Children are not allowed to register directly with any 3C Service. All registrations must be made by a parent or guardian. 3C never contacts children directly without the prior consent of a parent, guardian, or other qualified entity.
• Data generated about a child is set forth above in this Privacy Policy.
• We only share Data with parents, guardians, educators, or other authorized third parties. We only disclose personal information if permitted and/or required by law.
• Parental controls – At any time, parents can refuse to permit us to collect further personal information from their children in association with a particular account and can request that we delete from our records the personal information we have collected in connection with the account.
• Permissions needed for educators to allow students to use student accounts on Services, include:

1. 1. Teachers must work with their administrator to determine if they already have proper permission to allow their students to use Services.
   2. Schools must obtain parental consent if they set up student accounts on behalf of their students and allow students under the age of 13 to access student accounts in the classroom to use features. 3C obtains parental consent directly from a child’s parent if the parent (and not the teacher) sets up their child’s account, or if a student creates his or her own account on the Services.
   3. In some cases, teachers may obtain parental consent in what is commonly referred to as “school consent” under COPPA, where teachers have certified that they have directly received parent consent for their child to use Services for education purposes or may choose to act as the agent of the parent and consent on the student’s behalf.

13. EU user Consent

If Regulation (EU) 2016/679, the General Data Protection Regulation (“GDPR”), applies, users located in the European Economic Area (EEA) consent to 3C’s data collection, sharing, and usage as described in this Privacy Policy, and also consent to 3C’s storing and accessing of cookies as described in this Privacy Policy. Any EU user not consenting to such uses of data and cookies by 3C should not use this Service.

3C complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, visit https://www.privacyshield.gov/.

In compliance with the Privacy Shield Principles, 3C commits to resolve complaints about our collection or use of your personal information.  European Union individuals with inquiries or complaints should first contact 3C at:

Email: support@3cisd.com

Phone: 1-984-316-0406

Mailing Address: 3C Institute,

2645 Meridian Parkway, Suite 350, Durham, NC 27713

3C has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit JAMS for more information or to file a complaint.  The services of JAMS are provided at no cost to you.  Contact JAMS online at https://www.jamsadr.com/file-an-eu-us-privacy-shield-claim.

The Federal Trade Commission has jurisdiction over 3C’s compliance with the Privacy Shield.

14. EU Data Subjects

3C respects the rights of EEA residents to access, correct, and request erasure or restriction of their personal information if GDPR is applicable. If you are a resident of the EEA, you generally have a right to know whether or not 3C maintains Your Data. If Your Data is incorrect or incomplete, you have the right to ask 3C to update it. You have the right to object to 3C’s processing of Your Data. You may also ask 3C to delete or restrict Your Data. To exercise these rights, please contact 3C via email at support@3cisd.com. Please understand that 3C may need to verify your identify before processing your request.

15. How We Protect Your Personal Data

We maintain reasonable risk-based physical, technical, and administrative safeguards to protect against unauthorized and accidental disclosure, use, alteration, or destruction of Data in our possession, and to maintain the confidentiality, integrity, availability, and resilience of our systems, data, and services. We restrict access to Data to those individuals and third parties that need to know the information to accomplish the business purposes described in this Privacy Policy. We are committed to taking appropriate measures to enforce compliance with this Privacy Policy. In addition, we comply with applicable law for protecting Data.

Credit card data is transmitted using Secure Socket Layer (“SSL”) encryption or Transport Layer Security (“TLS”). Purchaser Data is a high priority and we use our own protective measures, as well as the capabilities of our software and hardware vendors.

We provide reasonable security controls to protect electronic Data that we receive from you against foreseeable hazards, but please note that no data transmission over the Internet can be guaranteed to be 100% secure. In addition, use of email to transmit Data is insecure and violates 3C policy. Therefore, we cannot ensure or warrant the security of any Data you transmit to us and you understand that any Data you transfer to 3C is done at your own risk.

We realize there can be incidents of misuse or unauthorized program incursions, as almost every website, service, and user encounters. In those instances, our goals are to move quickly to isolate the problem, ensure or restore proper functionality, and minimize any inconvenience to our users. As appropriate and necessary, 3C will notify the relevant authorities of these incidents of misuse or unauthorized program incursions of the Service.

16. Changes in Our Privacy Policy

3C reserves the right to make changes to our Privacy Policy at any time and for any reason without prior notice. Any changes to our Privacy Policy will be posted on this page and other places we deem appropriate so that you remain aware of our current Policy. We may also contact you by email with changes. Additionally, we will update the “last updated” date below.

17. Assignment

In the event that all or part of our assets are sold or acquired by another party, or in the event of a merger, you grant us the right to transfer the Data collected via Services.

18. Contacting 3C

You may contact 3C through email at support@3cisd.com or by calling 1-984-316-0406 with any questions or complaints regarding this Privacy Policy. You may also mail us directly at 3C Institute, 2645 Meridian Parkway, Suite 350, Durham, NC 27713.

If you believe you have not received an appropriate response from us regarding your question or complaint, and if you are an EEA user, you may contact the applicable supervisory authority below based on your residence:

• EU Data Protection Authorities (DPAs) (http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080)

Last Updated:  January 10, 2019