EPS Website and Commerce Privacy Policy

Last revised: December 1, 2023

Overview

This Website and Commerce Privacy Policy (“Privacy Policy”) describes the data protection practices of EPS Operations, LLC. and its affiliates (“EPS,” “we,” “us” or “our”), we take privacy and data security seriously. This Privacy Policy describes how we protect and how we use your information. This Privacy Policy applies to information that we collect related to your access or use of the EPS website at epslearning.com and related websites and digital properties that link to this Privacy Policy, and online or offline services related thereto. We refer to these products and services collectively as the “Services.”

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION.

This Privacy Policy contains the following sections:

• EPS Website and Commerce Privacy Policy
• Overview
• Summary
• What information do we collect about you?
• Why do we collect your information?
• Online analytics and advertising
• Who do we disclose your information to?
• Your use of the information of others
• International transfers
• Legal bases for use of your information
• Third-party links
• Security
• Information retention
• Your rights and choices
• Updates
• Additional privacy information for California residents
• Children’s Privacy
• Contact Us

Summary

We capture, manage and store information from and about you as part of our normal operations and service offerings. This Privacy Policy describes why we capture, how we use, and the circumstances under which we may disclose your information.

By visiting or registering on our website, or by using our Services, regardless of the manner or device made available and supported by us through which you choose to do so, you are agreeing to our Commerce Terms and Conditions and this Privacy Policy. You also agree that your information may be processed by us or on our behalf in the country where it was collected as well as other countries (including the United States) where laws regarding the processing of information may be less stringent than the laws in your country. We assume certain responsibilities and make related commitments to you. We are not liable with respect to misuse of the site by you or others and any other third party risks beyond our control that may affect your information.

If you access the Services as an employee or agent on behalf of an institution (an “Institution”) and there is an agreement between the Institution and EPS, then your use of the Services is also governed by the applicable agreement(s), which may include applicable privacy-related provisions.

If you have concerns about our privacy practices, you should contact us at privacy@epslearning.com. If you do not agree with the Commerce Terms and Conditions or this Privacy Policy, please do not use our Services.

What information do we collect about you?

Information you provide to us

• Information to identify and contact you, including your name, mailing address, phone number, and email address.
• Professional information such as the name of the Institution you are acting on behalf of, position, business address, phone number, and email as well as information that concerns the relationships between yourself and other individuals and organizations.
• Financial and transaction information, including cardholder name and number, billing address, and in some instances, Institution account or purchase order number.
• Registration or login information to access the Services and create a profile.
• Information you may provide or upload in order to enable us to provide you with our Services.
• Information you provide as you interact with the Services, such as ratings, reviews, recommendation, and other public feedback.
• Information about you when you request information about products and services, participate in our marketing, sales or other promotional activities, and respond to surveys or communicate with us, including though a chat function.
• Conference and event information, if you register for or attend a conference or event that we host, sponsor, or attend, we may receive your information. We may also collect information at such events, such as still images or audiovisual materials depicting you.
• Order information when you place an order through the Services.
• Information when you participate in a sweepstake or contest.

We also collect information from suppliers, vendors, business partners, and similar businesses, including in the following contexts:

• If you are a company or other organization that we engage with not in relation to use of our Services, or personnel of the foregoing, we may collect your name, phone number, email address, and postal address, government identifier, and business name, industry, locations, other information related to your employer, and any other information you choose to provide us, including through third-party portals and platforms.
• If we need to make payments to you or receive payments from you, we may collect financial account and related transactional information.
• If you contact us, we may receive information such as your name, email address, and phone number. We also will receive the contents of any communications you have with us. This might include requests, questions, and/or issues regarding your orders, your account, our Services, or other topics you might raise.

Information we collect automatically about you

We and our service providers may also automatically collect information from you in relation to your use of the Services or engagement with us:

• Usage Data. We and our service providers may collect and analyze information about how you use our Services. This information includes the dates and times you access our Services, the features you use and the pages you visit, the type(s) of browser through which you access our Services, the number of clicks, files you download, landing pages, the content you upload or post to our Services, error logs and other system activity, online browsing behavior data or clickstream data (e.g., date and time of access, referring and exit pages and URL, pages viewed, features used, cursor movements and clicks, customer service interactions and other uses of chat functionality, and the websites or applications through or from which you access our Services. We also collect and analyze information about your transactions through our Services, including the type of services you requested or received, the date and time for which an order was placed or requested, and the amount charged.
• Device Data. We and our service providers collect and analyze information about the device(s) you use to access our Services. This information might include your IP address, information about your device’s hardware, the operating system on your device and the version of that operating system, your language preferences, unique device identifiers, advertising identifiers, and information about the mobile network you use.
• Location Information. When you use the Services, we and our service providers may collect general location information from your computer or mobile device. “General” location information means information to identify the city and state in which your device is located based on its IP address. This information allows us to give you access to content that varies based on your general location (e.g., nearby locations).
• Information from Cookies and Similar Technologies. We and our service providers may collect information through the use of “cookies” and similar technologies, such as tracking pixels, to understand how you navigate through and interact with our Services, to learn what content is popular, to enhance the Services and provide you with a more relevant and personalized experience, for authentication and advertising purposes, to save your preferences, for fraud detection and security, and to collect certain usage, device and location information as described above. We may also collect this kind of information when you interact with email messages or other communications we send you. Cookies are small text files that web servers place on your device; they are designed to store basic information and to help websites and apps recognize your browser. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be accessed every time you use our Services. Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads, and/or email; they are designed to collect usage information like ad impressions or clicks and email open rates, measure the popularity of our Services and associated advertising, and access cookies. We and our vendors (including Google Analytics) also use these technologies and the information collected by them for data analytics purposes. You can find more information about Google’s analytics practices at google.com/policies/privacy/partners. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser Add-on To generally update your cookies settings to notify you when a cookie is being set or updated or to disable cookies altogether, please consult your web browser settings. Please note that if you delete or choose not to accept cookies from us, you may miss out on certain features of our Services.

Information we collect from others

We may collect information about you from third parties, including the following:

• Business Partners, Service Providers, and Researchers. We use business partners, service providers (such as payment processors, survey providers, and analytics providers), and researchers to perform services on our behalf. Some of these partners may have access to information about you that we may or may not otherwise have (for example, where you sign up directly with or otherwise engage with that provider) and may disclose some or all of this information with us.
• Log-in Services and Social Network Information. When you "like" or "follow" us on Facebook, LinkedIn, X (Twitter), or other social media sites, we may collect some information from you including your name, username, email address, and any comments or content you post relevant to us. We may also collect information from your publicly accessible social media accounts. For a description of how social networking sites handle your information, please refer to their privacy policies and terms of use, which may permit you to modify your privacy settings.
• Other Account Holders, Visitors, or Institutions. Another account holder or organization (such as the Institution or other individuals at the Institution you are engaging with us on behalf of) may provide us with your information. If you submit someone else's personal information to us, you represent that you are authorized to provide this information to us.
• Other Sources. We may collect information, particularly contact and business information from conferences, events, sales partners, marketing vendors, providers of business contact information, public records and lists, and third-party databases such as marketing databases, and other sources.
• Affiliates. We may obtain information about you from our Affiliates.

Why do we collect your information?

We and our service providers collect, use and disclose your information for the following business and operational purposes:

• manage, verify, and authenticate your information, account, and interactions with us;
• provide you with the Services offered, including completing transactions and responding to your requests for information about the Service;
• troubleshoot and resolve problems;
• engage in analysis and research regarding use of the Services, develop new Services, and improve the usability, performance and effectiveness of our Services and business;
• customize the content you see on the Services and about the Services;
• gain insights into prospective customers that might have an interest in our Services;
• communicate with you about the Services;
• display public information you provide related to your use of the Services, like reviews and ratings about the Services;
• provide you with news, updates, and reminders related to our Services;
• enforce our Commerce Terms and Conditions;
• help us better understand your interests and needs, and improve the Services, including through research and reports;
• protect you and us from error and fraud;
• understand your needs and eligibility for Services;
• measure the effectiveness of our advertising and deliver relevant advertising to you;
• comply with any procedures, laws, and regulations which apply to us;
• resolve disputes, protect ourselves, users of our Services, and others, and establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others; and
• as otherwise described to you at the time of collection.

We may combine the information that we collect through the Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Policy.

We may also aggregate and/or de-identify information collected through our Services in such a way that the information cannot reasonably be linked to you or your device. We may use de-identified or aggregated data for any purpose, including for research and marketing purposes, and we may disclose such data to any third parties, including advertisers, promotional partners, sponsors, and others.

Online analytics and advertising

Analytics. We may use third-party web analytics services (such as those of Google Analytics) on our Services to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here. If you receive an email from us, we may use certain analytics tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.

Online Advertising. In using the Services, we may allow select third party advertising technology partners to place cookies or other tracking technologies on the browser of your device to collect information about you as discussed above. We sometimes also associate cookies with de-identified data linked to or derived from data you have submitted to us (e.g., your email address) and disclose such information with to advertising partners and vendors in hashed, non-human-readable form to provide you with more relevant ads when you visit other websites and mobile applications. These third parties may use this information to serve relevant content and advertising to you as you browse the Internet, and access their own cookies or other tracking technologies on your browser to assist in this activity. If you are interested in more information about these online advertising activities, and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative's Consumer Opt-Out link, the Digital Advertising Alliance's Consumer Opt-Out link, or Your Online Choices to opt-out of receiving tailored advertising from companies that participate in those programs. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. Please note that these opt-outs apply per browser and per device, so you will have to opt out for each device—and each browser on each device—through which you access our Services. If you use these mechanisms, you may still see advertising on our Services or across the Internet, but it will not be tailored to you based on your online behavior over time.

Do Not Track ("DNT"). DNT is a privacy preference that web users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our Services through cookies and similar technologies, and that is why we provide the variety of opt-out mechanisms listed above. However, we do not currently recognize or respond to browser-initiated DNT signals.

Communications from EPS. We may send you communications via email about our Services. You can opt out of receiving communications from us by changing your notification settings. If you wish to update your email marketing preferences, or unsubscribe, you can do so by clicking the unsubscribe link at the bottom of the email. Please note that even if you unsubscribe or opt-out, we may still send you service-related communications (e.g., if your credit card payment was declined). If you do not wish to receive them, you must delete your account with us.

Who do we disclose your information to?

We retain the right to manage our operations, including using service providers of our own choosing, to facilitate the development, hosting and ongoing support of our Services to meet our business goals. For example, we may use the services of third-party companies to perform services on our behalf, such as billing, payment processing, advertising, web and other analytics, data storage and processing, customer support, delivery services, security, fraud prevention, and other services. These services may or may not be located in the same jurisdictions or regions as the customers using our Services. We also may disclose your information to service providers such as billing and payments service providers, shipping and fulfillment providers, and analytics providers. Our employees, consultants, contractors, suppliers and partners, if authorized, may have access to our customer information or the systems storing it as part of and solely for the purposes of performing their jobs, or within the scope of their agreements with us. In all cases, we use reasonable efforts to ensure that your information is protected under contracts with these providers.

We may disclose your information to our parent company, any subsidiaries, joint ventures, or other companies under a common control with us (collectively, “Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy. In addition, in the event of the sale (of some or all of our assets), transfer, merger, reorganization, dissolution, or similar transaction involving our business (including in contemplation of such transactions), your information may be among the transferred business assets. If such transfer is subject to any mandatory restrictions under applicable laws, we will comply with those restrictions.

We may disclose your information to the Institution or other individuals at the Institution you are engaging with us on behalf of.

We will also disclose your information if we are required by law (including any generally applicable law or any specific court order or other legal process binding on us) or if we otherwise determine in good faith that such disclosure is necessary to resolve disputes and/or protect or defend the rights or property of EPS and other users. We will use reasonable efforts to make you aware of such disclosure promptly unless we are prevented from doing so.

We may also disclose your information to other unaffiliated third parties such as third party parties we collaborate with in connection with integration, co-marketing and certain other coordinated efforts.

If you consent to our disclosure of your information, we will disclose your information consistent with your consent.

If you provide feedback to us, we may use and disclose such feedback for any purpose, provided we do not use such feedback in a manner that identifies you.

As noted above, we may disclose data that we have aggregated and/or de-identified to any third parties, including advertisers, promotional partners, sponsors, and others.

Your use of the information of others

Please do not provide information of any third party without their permission. If you choose to provide information of any third party, we will assume that you have the necessary permission to provide us with that information (e.g., persons affiliated with your organization). You agree that, with respect to the information of other persons that you disclose to us, you have all necessary consents and rights to disclose that information to us for our uses as described in this Privacy Policy from time to time, and you agree that the indemnity you give to us in the Commerce Terms and Conditions applies to any non-compliance by you with respect to the foregoing.

International transfers

We are headquartered in the United States, and your information that we collect and process is retained and stored by us and our service providers in the United States and may also be maintained, processed, and stored in other jurisdictions that may have different data protection laws than those in the country in which you are located.

Where legally required, we will use an adequate transfer method. For example, whenever we transfer your information from an entity in the European Economic Area (“EEA”) and the United Kingdom (“UK”) to the United States, we may use standard contractual clauses approved by the European Commission which give your information the same protection it has in Europe or rely on another adequate mechanism. Where applicable, you are entitled, upon request, to receive a copy of the relevant safeguard (e.g., EU standard contractual clauses) that have been taken to protect your information during such transfer. For a copy of the relevant safeguard please contact us using the information in the “Contact Us” section below.

Legal bases for use of your information

The laws of some jurisdictions, including, the EEA and the UK require that companies only process your “Personal Data” (as that term is defined in the applicable law, like the EU General Data Protection Regulation) if they have a “legal basis” (or justifiable need) for processing your Personal Data. To the extent those laws apply, our legal bases for processing Personal Data are as follows:

• To perform our obligations pursuant to a contract (or pending contract) with you. For example, we will process your Personal Data to comply with the Commerce Terms and Conditions as part of entering into a contract with you, and to honor our commitments in any contracts that we have with you.
• For our legitimate interests or the legitimate interests of others. For example, we will process your Personal Data to: operate our business and our Services; identify and fix any issues with our Services; provide customer service; secure the Services; learn more about how our customers use the Services; perform internal analytics; improve the Services and users’ experiences; conduct marketing; provide you with certain information about new products, special offers or other information that we think you may find interesting using the email address which you have provided in accordance with applicable law; make and receive payments; comply with legal requirements and defend our legal rights; prevent fraud; engage in a business change (e.g., sale, merger); and to know the customer to whom we are providing Services.
• To comply with our legal obligations, such as our obligation to share data with tax authorities.
• With your consent. Where we rely on this basis, you may have the right to withdraw your consent at any time as described in the “Your rights and choices” section below.

Third-party links

The Services may contain links to a third-party website, plug-in, feature, or service. If you choose to use these sites or features, please note that we do not have control over the third parties that operate these websites and services and are not responsible for their content or privacy practices. We encourage you to read their privacy policies before using their websites or services or giving them your information.

Security

We take measures, including the implementation of physical, technical, and managerial safeguards, to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure, or access. However, no method of transmission over the internet, and no means of electronic or physical storage, is absolutely secure. By using our Services, you acknowledge and accept that we cannot guarantee the security of your information transmitted to, through, or on our Services and that any such transmission is at your own risk.

When you create an account, you may be prompted to create a username or password. You are responsible for maintaining the confidentiality of your account password and for any activity that occurs under your account. We are not responsible for any loss or damage arising from your failure to maintain the confidentiality of your password. We urge you to change your passwords often, use a combination of letters and numbers, and make sure you are using a secure browser. If you have reason to believe that your interaction with us is no longer secure or if you suspect someone else is using your account, please let us know immediately by contacting us as indicated in the “Contact US” section below.

Information retention

We retain your information as necessary to provide the Services and to fulfill the transactions you have requested, and for other necessary purposes such as complying with our legal obligations, resolving disputes, enforcing our agreements, and for fraud prevention and related security purposes. In determining how long to retain information, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process the information, applicable legal requirements, and our legitimate interests. For example, we retain your email address as an authentication credential (where applicable) as long as you have an account with us and an additional period of time after that for our legitimate interests and for our fraud and legal compliance purposes. If you opt out of email marketing, we maintain your email on our suppression list for an extended time to comply with your request. We may delete or de-identify your information sooner if we receive a verifiable deletion request, subject to exemptions under applicable law. We may retain cached or archived copies of your information. Aggregated or anonymous data derived from your information, which cannot be traced back to your account, may remain on our production servers indefinitely. We reserve the right to use any aggregated or anonymous data derived from or incorporating your information.

Your rights and choices

Account Information

To keep your information or information pertaining to an Institution associated with your account accurate, current, and complete, delete such information, or restrict us from further collecting or using such information, you may use the settings presented in your account. For additional requests, please contact us through the Services or using the information in the “Contact Us” section below.

Data Subject Rights

Depending on your jurisdiction, you may have the right, in accordance with applicable data protection laws, to make requests related to your “personal information” or “personal data” (as such terms are defined under applicable law, and collectively referred to herein as “personal information”). Specifically, you may have the right to ask us to:

• Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we disclose personal information.
• Provide you access to and/or a copy of certain personal information we hold about you.
• Correct or update personal information we hold about you.
• Delete certain personal information we have about you.
• Provide you with information about the financial incentives that we offer to you, if any.
• Restrict or object to certain uses of your information.
• Opt you out of the processing of your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable.

If you are a California resident, please see the “Additional privacy information for California residents” section below for more information about our privacy practices and your rights. As provided in applicable law, you also have the right to not be discriminated against for exercising your rights.

Please note that certain information may be exempt from such requests under applicable law. For example, we may be required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives to be overwritten or deleted in the ordinary course. We may also retain your information for fraud or similar purposes.

We also may need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address. If we are unable to verify you, we may be unable to respond to your requests.

You may be able to designate an authorized agent to make requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.

To exercise any of these rights, you can contact us at privacy@epslearning.com.

Depending on applicable law, you may have the right to appeal our decision to deny your request. We will provide information about how to exercise that right in our response to denying the request. To exercise such an appeal right, emails us as privacy@epslearning.com. In addition, you may have the right to file a complaint with regulatory authorities with respect to our data processing, and our legal basis for processing.

If we are processing your information as a service provider to a customer, you should contact the entity that collected your information in the first instance to address your rights with respect to such data.

Notice of right to opt out of sales of personal data and processing/sharing of personal data for targeted advertising purposes

Depending on your jurisdiction, you may also have the right to opt out of “sales” of your information and “sharing/processing of your information for targeted advertising.”

As explained in the “Online analytics and advertising” section above, we provide information to third-party advertising providers for targeted advertising purposes and use advertising analytics partners to assist us in analyzing use of our Services and our user/customer base. Under applicable law, the disclosure of your personal information to these third parties to assist us in providing these services may be considered a “sale” of personal information or the “sharing/processing of your information for targeted advertising.”

If you would like to opt out of our online disclosure such as through cookie and pixel technology of your personal information for purposes that could be considered “sales” for those third parties' own commercial purposes, or “sharing” for purposes of targeted advertising, please review the information and follow the instructions in the “Online Analytics and Advertising” section above. You must make this choice on each site/app on each browser/device you use to access the Services. You must also renew this choice if you clear your cookies or your browser is set to do that. You can also submit a request to opt out of the use of your email address and other personal information related to that email address for targeted advertising purposes by visiting https://shop.epslearning.com/contact-us. Depending on your jurisdiction, you may be permitted to designate an authorized agent to submit such requests on your behalf. Please note that we do not knowingly sell the personal information of minors under 16 years of age.

Notice of financial incentives

We may offer opportunities to receive certain services or benefits, including money to participate in surveys, sign up for communications, or other similar incentives, which may require the provision of personal information, such as registering for an account and answering surveys or providing additional feedback or information. Such opportunities could be considered a financial incentive under applicable law (each, an “Incentive Program”). Your participation in Incentive Programs is purely voluntary. When you participate in an Incentive Program, you agree to the terms of that Incentive Program, and may revoke your participation depending on the Incentive Program.

Updates

We reserve the right to amend this Privacy Policy at any time. We will make the revised Privacy Policy accessible through the Services, so you should review the Privacy Policy periodically. You can know if the Privacy Policy has changed since the last time you reviewed it by checking the “Last Updated” date at the beginning of this Privacy Policy. If we make a material change to this Privacy Policy, we will provide you with notice in accordance with legal requirements. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Privacy Policy.

Additional privacy information for California residents

If you are a California resident, the California Consumer Privacy Act (“CCPA”) requires us to provide you with the following additional information about: (1) the purpose for which we use each category of “personal information” (as defined in the CCPA) we collect; and (2) the categories of third parties to which we (a) disclose such personal information for a business purpose, (b) “share” personal information for “cross-context behavioral advertising,” and/or (c) “sell” such personal information. Under the CCPA, “sharing” is defined as the targeting of advertising to a consumer based on that consumer’s personal information obtained from the consumer’s activity across websites, and “selling” is defined as the disclosure of personal information to third parties in exchange for monetary or other valuable consideration. Our use of third-party online advertising services, which are described in detail above, may result in the disclosure of online identifiers (e.g., cookie data, IP addresses, device identifiers, and usage information) in a way that may be considered a “sale” or "sharing" under the CCPA.

The following chart provides information about our practices in the 12 months leading up to the effective date of this Privacy Policy:

For more information about each category of personal information, purpose of use, and third parties to which we disclose personal information, please see the “What information do we collect about you?,” “Why do we collect your information?,” and “Who do we disclose your personal information to?” sections of our Privacy Policy.

Your Choices Regarding “Sharing” and “Selling”

As explained in the “Online analytics and advertising” section above, we provide information to third-party advertising providers for targeted advertising purposes and use advertising analytics partners to assist us in analyzing use of our Services and our user/customer base. Under applicable law, the disclosure of your personal information to these third parties to assist us in providing these services may be considered a “sale” of personal information or the “sharing/processing of your information for targeted advertising.”

If you would like to opt out of our online disclosure such as through cookie and pixel technology of your personal information for purposes that could be considered “sales” for those third parties' own commercial purposes, or “sharing” for purposes of targeted advertising, please review the information and follow the instructions in the “Online Analytics and Advertising” section above. You must make this choice on each site/app on each browser/device you use to access the Services. You must also renew this choice if you clear your cookies or your browser is set to do that. You can also submit a request to opt out of the use of your email address and other personal information related to that email address for targeted advertising purposes by visiting https://shop.epslearning.com/contact-us. Depending on your jurisdiction, you may be permitted to designate an authorized agent to submit such requests on your behalf. Please note that we do not knowingly sell the personal information of minors under 16 years of age.

Other CCPA Rights

If we ever offer any financial incentives in exchange for your personal information, we will provide you with appropriate information about such incentives.

Please see the “Your rights and choices” section of our Privacy Policy above for information about the additional rights you have with respect to your personal information under California law and how to exercise them.

Retention of Your Personal Information

Please see the “How long do we retain your information?” section above.

Shine the Light Disclosure

The California "Shine the Light" law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we disclose certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We currently do not disclose your personal information to third parties for their own direct marketing purposes.

Children’s Privacy

If you are under 18 years of age, you are not authorized to use the Services, with or without registering. As such, the Services are not directed to children under 13 years old and we do not knowingly collect or maintain personal information from children under the age of 13. If we nevertheless discover that the Services have received personally identifiable information (as defined by the United States Children’s Online Privacy Protection Act) in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account. If you believe that we may have personal information from a person under 13, please contact us using the information in the Contact Us section below.

Contact Us

EPS welcomes your comments and questions regarding this Privacy Policy and the use of your information. If you have questions, concerns or if you would like more detailed information, please email us at privacy@epslearning.com.