PERSONAL INFORMATION WE COLLECT AND PURPOSES
The tables below explain the categories of information we collect and the purposes for which we use them. Please note that we may use any or all of this information to comply with the law, detect or prevent fraud, for safety and security purposes, and to defend our legal rights. Further detail about each of the purposes is set out in the “Additional Information on Purposes” table below.
Categories of Personal Information We Collect
Purposes of Use
Contact and Account Registration Information
For example: name, email address, account username and password, and any other information you may provide to us
For example: payment method information (e.g. credit/debit card details)
Device information and identifiers
For example: IP address, cookie IDs, browser type and language, operating system, platform type, device type, and advertising and app identifiers
Connection and Usage (including information collected through cookies)
For example: domain names, browsing activity, scrolling and keystroke activity, advertisements viewed, forms or fields you complete or partially complete, search terms, whether you open an email, content you view and duration, quality of the service and interaction with the content, logs, and other similar information. If these events occur while you are offline, they may be logged and uploaded to us when you next connect
WHEN WE SHARE YOUR INFORMATION
We may disclose your information to:
Related Companies: Socrates affiliates, including its fiscal sponsor Capstone Legacy Foundation, to help better tailor services, products, marketing, and advertising to you and to other existing and potential customers. We may share identification and demographics, device information and identifiers, and research and feedback for purposes such as improving and tailoring services. In addition, business information may be shared for business operational purposes.
Service Providers: We amy engage vendors to perform business purposes on our behalf and provide information to them to enable them to provide us with such business purposes, including research and analytics, hosting, transaction and payment processing, promotion administration, fraud prevention, identity management, acquisition and other services. Service providers may use such information for their operational purposes in order to provide their services to us.
Law Enforcement, Regulators, Anti-fraud Coalitions and other groups: We may disclose the categories of information we collect, as appropriate, with these third parties in order to protect and enforce the legal rights, privacy, and safety of ourselves and our visitors; protect against possible fraud or other illegal activity; respond to requests from government and other authorities; and otherwise comply with legal process.
Sale or transfer of all or part of our business or assets
LEGAL BASIS FOR USE OF YOUR INFORMATION
The laws of some jurisdictions, such as the European Union, the UK, or Brazil, require companies to tell you about the legal basis for using, sharing, or disclosing your information. To the extent those laws apply, we may rely on the following legal bases:
Legitimate interest: where use of your information is necessary for our or others’ legitimate interests and where the use is not outweighed by your rights and interests. Below are some examples of such interests:
- providing Socrates Plus Services
- improving our Services and developing new ones
- recognizing and better understanding our users, including across platforms
- conducting security and fraud prevention activities
- marketing and promoting our content and services
- building and managing business-to-business relationships
- conducting compliance and risk management activities
- providing and managing access to our systems
Legal obligation: where use of your information is necessary to comply with laws and regulations such as those relating to anti-bribery and corruption and anti-money laundering, complying with requests from government bodies or courts, or responding to litigation.
With consent: we may ask for your consent to process your information in a certain way. Where we rely on this basis, you have the right to withdraw your consent at any time – please see the Your Rights and Your Choices sections below to do this.
Most of the Socrates Plus Services are intended for users over the age of 15. If you are a parent or guardian and believe your child under 13 in the United States or under 16 in the European Union has provided us with personal information without consent, please contact us at firstname.lastname@example.org.
This section outlines our information practices in the United States with respect to personal information (as defined by the Children’s Online Privacy Act (“COPPA”)) collected online from services directed to children under the age of 13 or from children who we have actual knowledge are under the age of 13 (“child” or “children”). For more information about COPPA, see FTC – Children’s Privacy.
If we knowingly collect personal information on a child-directed service or from a user we have actual knowledge is a child, we will retain that information only so long as reasonably necessary to 1) fulfill the request or allow the child to participate in the activity, 2) ensure the security of our users and our online services, and/or 3) as required by law. If we learn we have collected personal information from a child in a manner inconsistent with COPPA’s requirements, we will either delete that personal information or seek parental consent.
Collection and Use of Personal Information from Children
If an online service seeks to collect personal information from a child that is not subject to an exception under COPPA, we will first ask for a parent or guardian’s consent to that collection as required by law.
Our online services directed to children may collect the following information from children for the purposes described:
- Registration Information: Children may be able to register with an online service to view content. We may ask the child to provide a screen name (that does not include the child’s name) and password. We may also request information for notification purposes, such as a parent or guardian’s email address, the child’s first name and gender, and birth date. We may ask for a child’s email address for purposes of generating a password reminder. In such cases, unless we otherwise obtain consent or notify the parent of ongoing communications (as discussed below), we will hash such email address such that it can only be used as a password reminder and cannot be used to contact the child.
- Email Address for One-Time Response: We may ask for a child’s email address or other online contact information in order to respond to a question or request from a child. We will delete this information after responding to the question or request. If an online service allows children to create accounts by providing name and email address, we will first seek parental consent as required by COPPA.
- Email Address for Newsletters or Other Ongoing Communications: Our online services may offer ongoing communications to our users, such as newsletters or show updates. In such circumstances, we may collect a child’s email address or other online contact information, along with a parent’s email address. We will notify the parent via email about the collection and use of the child’s information and provide the parent an opportunity to prevent further contact with the child.
- Information to Obtain Parental Consent: We may ask a child for a parent’s or guardian’s email address or other permissible contact information in order to request consent. If we do not receive parental consent within a reasonable time, we will delete the contact information and any other related information collected from the child. We may conduct other methods of parental consent permitted by COPPA, including obtaining a credit card number and charging a fee (which may be nominal), asking a parent to speak to a customer service representative by phone or video, or requiring submission of a signed consent form.
- Persistent Identifiers: Our online services may automatically collect persistent identifiers for internal operations, including to provide and improve our online services, conduct analytics, authenticate users, personalize content, maintain the security and integrity of the service, and to ensure legal or regulatory compliance. Specifically, we may collect Internet protocol or IP address, pages and content visited, the type and version of operating system or web browser, device ID. We, or our third party service providers, may collect this information using HTTP cookies, flash cookies, HTML5 and Flash local storage, web beacons/GIFs, embedded scripts, and ETags/cache browsers (“Cookies”).
Disclosure of Personal Information from Children
We may share or disclose personal information collected from children in the following circumstances:
- With our service providers in order for them to perform service on our behalf;
- As permitted or required by law, including in response to a court order or a subpoena.
- To protect the safety of a child, to prevent a crime, or to facilitate a public safety investigation;
- To take precautions against liability; or
- To protect the security or integrity of our online services.
In addition, personal information collected from a child may be shared or publicly posted if we first obtain parental consent.
Parents or guardians may contact us via email at email@example.com to review personal information provided by his or her child, have such information deleted, and/or refuse to allow further collection or use of such information.
Depending on where you live, you may have certain rights with respect to your information. You have the right not to be discriminated against (as provided for in applicable law) for exercising your rights under some local laws such as in California.
For example, under local laws, including in the European Union, you may be able to ask us to provide access to certain information we hold about you, in some cases in a portable format, if technically feasible update or correct your information delete certain information restrict the use of your information.
We will respond within the time period prescribed by applicable law. Please note that the above rights are subject to exceptions and limitations.
Some Socrates Plus Services can only be provided if we have your information, therefore deletion of your information will result in termination of such Services.
We may take reasonable steps to verify your identity, including authenticating you through the email address. We may require further documentation such as a password and user ID before granting access to your information.
To make access, correction or deletion requests, or if you are based outside the U.S. and would like to exercise any individual right, please email us at firstname.lastname@example.org.
Your rights and our responses will vary based on your state or country of residency. Please note that you may be located in a jurisdiction where we are not obligated, or are unable, to fulfill a request. In such a case, your request may not be fulfilled. If you have any unresolved concerns, you may have the right to complain to your data protection authority.
Socrates does not engage in the following activity, however Nevada law requires us to post the following: certain Nevada consumers may opt out of the sale of “covered information” for monetary consideration to a person for that person to license or sell such information. “Covered information” includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online.
If you are a Nevada resident who has purchased goods or services from Socrates, you may submit a request to opt out of any potential future sales under Nevada law by emailing us at email@example.com. We will maintain your request in the event our practices change.
Cookies and Similar Technologies
The Services use the following types of first and third-party Cookies for these purposes:
- Strictly Necessary Cookies: These Cookies are required for Service functionality, including for system administration, security and fraud prevention, and to enable any purchasing capabilities. You can set your browser to block these Cookies, but some parts of the site may not function properly.
- Information Storage and Access: These Cookies allow us to store and access information on the device, such as device identifiers.
- Measurement and Analytics: These Cookies collect data regarding your usage of and performance of the Services, apply market research to generate audiences, and measure the delivery and effectiveness of content and advertising. We use these Cookies to perform analytics, so we can improve the content and user experience, develop new products and services, and for statistical purposes. They are also used to recognize you and provide further insights across platforms and devices for the above purposes.
- Personalization Cookies: These Cookies enable us to provide certain features, such as determining if you are a first-time visitor, capping message frequency, remembering choices you have made (e.g., your language preferences, time zone), and assist you with logging in after registration (including across platforms and devices). These Cookies also allow your device to receive and send information, so you can see and interact with ads and content.
- Content Selection and Delivery Cookies: Data collected under this category can also be used to select and deliver personalized content, such as news articles and videos.
Depending on where you live, you may be able to adjust your Cookie preferences at any time via the “Cookie Settings” link in the footer of relevant websites. You can also use the methods described below to manage Cookies. You must take such steps on each browser or device that you use. If you replace, change or upgrade your browser or device, or delete your cookies, you may need to use these opt-out tools again. As some Cookie-management solutions also rely on Cookies, please adjust your browser Cookie settings carefully, following the relevant instructions below.
Browser Controls: You may be able to disable and manage some Cookies through your browser settings. If you use multiple browsers on the same device, you will need to manage your settings for each browser. Please click on any of the below browser links for instructions:
Microsoft Internet Explorer
If the browser you use is not listed above, please refer to your browser’s help menu for information on how to manage Cookies. Please be aware that disabling cookies will not disable other analytics tools we may use to collect information about you or your use of our Services.
Flash Local Storage: These cookies are also known as local shared objects and may be used to store your preferences or display content by us, advertisers and other third-parties. Flash cookies need to be deleted in the storage section of your Flash Player Settings Manager.
Consequences of Deactivation of Cookies: If you disable or remove Cookies, some parts of the Services may not function properly. Information may still be collected and used for other purposes, such as research, online services analytics or internal operations, and to remember your opt-out preferences.
Mobile App and Connected Devices
Depending on the device you use, you may be able to manage your preferences through your device settings. You should review your device manufacturer’s support materials and/or the device settings for the respective operating systems for more detail on how to manage such preferences.
You can stop all collection of information by a mobile app by uninstalling the app.
HOW WE PROTECT YOUR INFORMATION
We maintain organizational, technical, and physical safeguards to help protect the information we collect and use. These safeguards vary depending upon a variety of factors including the sensitivity of the information we collect and use. Despite all reasonable practices, no security method is infallible.
HOW LONG WE KEEP YOUR INFORMATION
We will keep your information only for as long as it is necessary to fulfill the purposes described above, unless a longer retention is required or permitted by law. 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. The purposes for which we process information (as well as the other factors listed above) may dictate different retention periods for the same types of information. 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. The retention period that applies to your information may vary depending on the Socrates Plus Services you use and how you interact with them. Some Socrates Plus Services may provide additional details on their data retention practices, so we encourage you to consult their website and/or FAQs. In addition, in the event you have an account that holds credits, point balances or other entitlements, we may continue to hold the account to allow you to obtain the benefit in accordance with the relevant terms and conditions.