eduPresent, LLC dba Bongo is committed to protecting the privacy of our users. Please review this Privacy Statement carefully to understand how the information you provide to us will be treated.
This Privacy Statement applies to Personal Information collected (1) on Bongo websites and other sites that we own or control, including www.bongolearn.com or other Bongo websites, (2) for or by Moodle enterprise offerings that may be hosted by Bongo or (3) third-party service providers. There are two main classes of users of Bongo offerings: Learning Management Service (LMS) integrated users and consumer users. LMS integrated users access Bongo offerings by virtue of an agreement that we have with the user’s institution (educational or otherwise), employer, or other organization (“Organization”). Consumer users are visitors to Bongo websites, or persons who access Bongo offerings by virtue of an agreement directly with us.
If you were given access by an organization as an LMS integrated user or as a parent or guardian of an enterprise user, this privacy statement does not affect or control the organization’s collection, use, or disclosure of your information. You should contact your organization to find out its practices regarding your Personal Information.
Personal Information means any information about an individual who is either directly or indirectly identified by the information or could be reasonably identified by it. Personal Information includes information that relates to an individual’s personal characteristics (e.g. gender, age, income, home address, personal phone number, identification number, location data, an online identifier, ethnic background, family status, etc.), health (e.g. health history, health conditions, health services received, etc.), or activities and view (e.g. religion, politics, opinions expressed by the individual, etc.) This privacy statement does not apply to information we collect in the aggregate. Aggregated information does not identify you as an individual.
By providing any Personal Information to us, or sharing Personal Information with others (including sensitive information) using a Bongo offering or Bongo website, you expressly and voluntarily consent to the storage and processing of that Personal Information by us in accordance with the terms and conditions of this privacy statement and any applicable user agreement (including an end user license agreement or service agreement) that allows us to store and process Personal Information about you. When you provide Personal Information, that Personal Information may reside on our or our service providers’ systems. You understand and agree that Personal Information collected through Bongo offerings and Bongo websites may be stored and processed by us, our affiliates, or our service providers in Canada, the United States, Ireland, Australia, or other countries, including countries other than your country of residence; the laws of the jurisdiction in which the Personal Information is stored and processed will apply to its storage and processing. If you are a user of Bongo’s products and services, the location of your Personal Information and the laws that apply to its storage and processing may be subject to a contract between Bongo and your organization.
We may collect Personal Information from you in the following ways:
REGISTRATION AND PROFESSIONAL SERVICES
In order to access some Bongo offerings, you may be asked to create an account which will require you to provide us with Personal Information. Certain Bongo offerings enable you to provide additional information voluntarily. Providing information beyond what is required at registration is up to you but providing such information may enable you to derive more benefit from Bongo offerings. We may collect Personal Information about you if your organization has contracted with us for professional services or end-user support, or if you are an approved support contact under our agreement with your organization. Any Personal Information collected in connection with our provision of professional services to your organization is collected for the purpose of providing such services to your organization efficiently and effectively. Any information collected through the use of our support service is intended to help resolve issues as quickly as possible, and to ensure that you can be notified of the progress of any issues that you describe.
WEBSITES, ECOMMERCE AND OTHER MARKETING INITIATIVES
Within some Bongo websites, we ask you to provide Personal Information.
We may collect Personal information from you such as your name, email address, telephone number and organization information when you sign up for webinars, product trials, newsletters, or download white pages
When you join or post information to one of our communities, you share your profile information, including Personal Information that you choose to share with other community members. When you submit an application or inquiry through our careers site, you voluntarily provide Personal Information to us
When you post a comment on our company blog, you share Personal Information within your comment with the general public.
COOKIES AND WEB BEACONS
Like most websites, we use technologies, such as cookies and web beacons, to collect information about our pages you view, the links you click, and other actions you take in using Bongo offerings and Bongo websites.
INFORMATION COLLECTED BY YOUR ORGANIZATION OR THIRD PARTIES
If you are an enterprise or Moodle user, your organization may collect Personal Information on its own through the use of Bongo offerings. Collection and use of Personal Information in this way is governed by the privacy policies of your organization.
We use tools to help us analyze how Bongo offerings and Bongo websites are used, and to help us develop and optimize our Bongo offerings and Bongo websites. We also use Google Analytics among other tools to improve our offerings and our websites. See http://www.google.com/analytics/terms/us.html for more information about Google Analytics.
HOW WE USE YOUR INFORMATION
If you are an enterprise or Moodle user:
Your organization may use Personal Information that it has collected through the use of Bongo offerings in a manner that is different from what is set out in this privacy statement. Any use of your information by your organization is subject to the privacy policies of your organization.
If your organization is a school in the United States, our provision of services may involve us having access to student education records subject to the US Family Educational Rights and Privacy Act (FERPA), 20 U.S.C. 1232g, et seq. Under FERPA, we are deemed a “school official” to the extent we have access to student education records, and we will not use such student education records for any purpose other than to perform our agreements with you or as otherwise mandated by applicable regulations.
Beyond the Personal information that you directly provide to use Bongo products and services, we infer data based on your usage. Monitoring information such as IP addresses, the date/time of actions being taken, and what features are being used help us deliver great experiences. For example, having a historical record of the number of logins that occur over the months of August and September assists us in making sure our systems are ready during the typical semester start period of North America. Bongo analyzes this type of data in aggregate and does not sell this Information to third parties.
If you are a direct user:
We may use your Personal Information to communicate with you. We may send certain service communications such as welcome letters, billing reminders, information on technical service issues, and security announcements. Some Bongo offerings may send periodic member letters that are considered part of the service. We may also send you promotional information to inform you of other Bongo offerings and promotions.
We use your information to operate and improve Bongo offerings and Bongo websites. These uses include providing you with more effective customer service, making Bongo offerings easier to use by eliminating the need for you to repeatedly enter the same information, performing research and analysis aimed at improving Bongo offerings and Bongo websites, and displaying content and advertising that are customized to your interests and preferences.
Some Bongo offerings are accompanied by interactive features such as chat rooms, forums, messaging and other ways to share. If you are an enterprise user, permissions as to what features are enabled and who has access to those features is determined by your organization. If you are a consumer user, it is your choice whether to use the available functionalities.
When you receive newsletters or promotional emails from us, we may use web beacons, customized links, or similar technologies to determine whether the email has been opened and which links you click in order to provide you more focused e-mail communications or other information.
COMMUNICATIONS WE SEND
We may communicate with you through email or other means available through a Bongo offering. We may send emails that help inform you about features of Bongo offerings and we may also send you service messages related to the function of Bongo offerings. We may send you messages with promotional information directly or on behalf of our partners.
If you sign up for webinars, product trials, newsletters, mailing lists, or other marketing initiatives through the Bongo websites, employees of Bongo may contact you with information about Bongo offerings and promotions that may be of interest to you. We may offer webinars, product trials, conferences and events, or other marketing initiatives with certain partners; in such cases, the information you submit upon sign-up is shared with the relevant partner(s).
SHARING YOUR INFORMATION WITH THIRD PARTIES
We may share your information with third parties who are not our partners or service providers only in the following situations:
As may be necessary in the course of providing our product offerings to you, we may disclose information to the payment processors, auditors, commercial partners, customer support providers, marketing and public relations companies, and operational services providers.
Mergers or acquisitions: As with any other business, it is possible that in the future, YouSeeU could merge with or be acquired by another company. If such an acquisition occurs, you consent to the successor company having access to the Personal Information maintained by Bongo, and such successor company would continue to be bound by this privacy statement unless and until it is amended.
Except as part of the sale of all or substantially all of our assets, we will not sell, trade, or rent your Personal Information to third parties who are not our partners or service providers unless we have your consent.
INFORMATION YOU SHARE WITH OTHER USERS
Bongo offerings may enable you to share Personal Information with or send communications to other users or the general public. You (or, if you are an enterprise user, your organization) may select the other users with whom you share or to whom you send this information. Once you share Personal Information with or send information to other users, however, those other users may share your Personal Information at their discretion.
ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
We offer users the ability to access or correct Personal Information we collect during registration or which they have provided in using Bongo offerings. Users may correct this information at any time and as often as necessary by using the features provided within the applicable Bongo offering. To access or correct Personal Information collected by us that is not available through a Bongo offering, please contact us at DPO@bongolearn.com. We will respond within a reasonable timeframe of receiving your request or as otherwise required by law.
We may decline to provide you with access to, or to change, your Personal Information if (a) your request is not provided in writing, (b) your request does not provide us with sufficient detail to identify the Personal Information you seek to access or change, (c) we are unable to verify your identity to our satisfaction, (d) we deem, in our sole discretion, that it would be unreasonable in the circumstances to provide you with access to or to correct your Personal Information, or (e) as otherwise provided by legislation.
If you are an enterprise user, you should contact your organization for questions about access to the Personal Information collected by your organization.
USER OPT-OUT OPTION AND RETENTION OF YOUR PERSONAL INFORMATION
You may opt out of receiving promotional information from us by following the unsubscribe procedures indicated in promotional information you receive.
If you are an enterprise user, retention of your Personal Information is governed by the privacy policies and is the responsibility of your organization. If you wish to remove your account, please contact your organization. If your organization retains the Personal Information, it is subject to our contractual arrangement with your organization and may be subject to our archival policies.
If you are a consumer user, we will retain your Personal Information for so long as you maintain an active account or user profile, or as needed to provide you with the applicable Bongo offering.
If you are a consumer user and you wish to remove or restrict the collection of data with an account you have with us, you may do so by contacting us at DPO@bongolearn.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce this privacy statement and any applicable user agreements or partner contracts. We will take steps to ensure that your Personal Information is destroyed, erased or made anonymous as soon as the purpose for which it was collected is no longer relevant, or as required by law.
Please be aware that, as long as you have access to Bongo offerings, you cannot opt out of receiving service messages from us. Also, if we send communications to you via the carrier service with which you have a mobile communications subscription or otherwise have access, you understand you will pay any service fees associated with your receipt of messages on your mobile device (including text messaging charges).
We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store Personal Information. For more information on our security, please visit www.bongolearn.com/security/.
We restrict access to Personal Information to Bongo employees, contractors and agents who have a need to know that information in order to process it on our behalf. These individuals are bound by confidentiality obligations and may be subject to discipline, up to and including termination, as well as civil action and criminal prosecution, if they fail to meet these obligations.
We do not guarantee that we will eliminate all risk of misuse of, or unauthorized access to, your Personal Information. There is no such thing as perfect security, and we cannot guarantee or warrant the security of any data (including Personal Information) that we receive and store on our or our service providers’ systems.
You are responsible for keeping any passwords secret to prevent unauthorized access to and use of any Bongo offerings to which you have access.
If you are an enterprise user, your organization is responsible for ensuring that the system is configured to properly restrict access to Personal Information in accordance with its own privacy statement or policy, and that anyone with access to that Personal Information is covered by its privacy statement or policy.
If you are an enterprise user, your organization may collect information on its own through the use of Bongo offerings. Collection of Personal Information in this way is at your organization’s discretion and is governed by the privacy policies of your Organization. Bongo offerings contain configuration options that your organization may use to align the Bongo offerings with organization policies.
We do not knowingly collect any Personal Information from individuals under the age of 13 through Bongo consumer offerings or Bongo websites. The Bongo websites are general audience websites.
To the extent that we store data with third party providers, we and our service providers comply with the principles of the EU-GDPR, U.S. and Swiss-U.S. Privacy Shield Framework, and Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA). In order to adequately protect data transfers originating from the EU, we will ensure that the country to which the data is transferred is approved by the European Commission as having a sufficient level of privacy protection, or we will use approved standard contractual model clauses.
We (specifically EduPresent LLC) and our service providers comply with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework principles as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information from the European Union and Switzerland to the United States.
If there is any conflict between the terms in this privacy statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern.
The Federal Trade Commission has jurisdiction over our compliance with the Privacy Shield. We may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We are responsible for any of your Personal Information that is shared under the onward transfer principle with third parties for external processing on our behalf, as described in the “use of Personal Information” section.
In compliance with the Privacy Shield Principles we commit to resolve complaints about our collection or use of your Personal Information. European Union individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at DPO@bongolearn.com or by using the contact information posted in the sections below.
For more information about the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield, or to access our Privacy Shield certification statement, please visit www.privacyshield.gov.
If you reside in the European Union, upon registration for any applicable YouSeeU offering you consent that the Personal Information you have provided may be transferred and stored in countries outside the EU under lawful data transfer mechanisms or to adequate jurisdictions only in compliance with the GDPR and EU-US Privacy Shield.
The European Union’s General Data Protection Regulation (GDPR) became effective on 25 May 2018. The GDPR protects European Union data subjects’ fundamental right to privacy and the protection of personal data.
The GDPR gives European data subjects the right to access and request deletion of their personal data. If you wish to request deletion of or obtain a copy of your Personal Information held by Bongo, please contact YouSeeU’s Data Protection Officer at DPO@bongolearn.com.
If you believe the processing of your personal data by Bongo is not in compliance with the GDPR after it became effective May 25, 2018, you have the right to lodge a complaint with a supervisory authority.
We keep our privacy statement under regular review. We reserve the right to modify or supplement this privacy statement at any time. If we make a change to this privacy statement, we will post such changes on our website.