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SurfWisely, Inc. (“SurfWisely,” “we,” “our”, or “us”), recognizes the importance of your personal privacy and is committed to respecting it. This Privacy Policy (“Privacy Policy”) explains how we collect, use, and disclose personal information when you use our website located at www.surfwisely.com (the “Website”), our products and services (including SurfWisely’s web-based educational applications, tools, and platforms that you have subscribed to or that we otherwise make available to you, and are developed, operated, and maintained by us (the “Subscription Service”)), and any other sites or services that link to this Privacy Policy (collectively, the “Services”).

We ask that you take the time to read this Privacy Policy carefully. By using our Services, you agree to this Privacy Policy, our Children’s Privacy Policy and our Terms of Service (collectively, the “Terms”). If you are using the Services on behalf of another party (including a School), you represent and warrant that: (i) you have all rights, consents, and permissions to do so; and (ii) that you have obtained such party’s express consent and agreement to the Terms. If you do not agree with this Privacy Policy, our Children’s Privacy Policy or the Terms of Service, please do not use the Services.

Table of Contents

1. Children’s Privacy

2. Changes to this Privacy Policy
3. What Personal Information do we collect?
4. How do we use your information?
5. In what situations do we share your personal information?
6. What are my information choices?
7. How do we keep information safe?
8. Contact Us

1. Children’s Privacy

Age Eligibility

Subscription Services may be purchased by providers of educational services, such as schools, school districts, or teachers (collectively referred to as “Schools”) that use our Services for educational purposes. Although some features of Subscription Services are intended for use by children and teens, SurfWisely does not permit children or teens under the age of 18 to register for the Services or create an account.

We do not knowingly collect personal information from children or teens without the consent and at the direction of a School. SurfWisely relies on each School to provide appropriate notice to parents of the School’s use of third party service providers, such as SurfWisely, that may collect or use personal information of students.  If you believe we have collected personal information from children or teens under the age of 18 without School consent, you may directly request the deletion of such information by contacting us.

For more information on SurfWisely’s practices with respect to the personal information of children, please see our Children’s Privacy Notice.

Student Data

When SurfWisely contracts with a School to provide the Service, a School may provide personal information about its students, including student names or other identifiers, passwords, e-mail addresses for the student or the student’s parent or legal guardian, and educational level (“Student Data”).  For example, the Services may collect Student Data when a School registers for the Service and creates a profile for a student.  Schools and/or students may have the option to enter school-provided student identification numbers, but please note that SurfWisely does not collect sensitive personal information of students and will not request social security numbers. Some Schools may elect to use a single-sign-on (SSO) service rather than usernames and passwords to authenticate student access.

We consider such Student Data to be strictly confidential and in general do not use Student Data for any purpose other than improving and providing our Services to the School or on the School’s behalf. Our collection, use and sharing of Student Data is governed by our contracts with the School and any applicable laws and regulations including, in the U.S., provisions of the Family Educational Rights and Privacy Act (“FERPA”), the Children’s Online Privacy Protection Act (“COPPA”) and applicable state laws. If you have any questions about reviewing, modifying, or deleting personal information of a student, please contact your School directly.

2. Changes to this Privacy Policy

This Privacy Policy is effective as of the date indicated above.  We encourage you to review this Privacy Policy whenever you access the Services to make sure that you understand our information collection, use, and disclosure practices. We may change this Privacy Policy from time to time and will indicate when changes have been made by revising the date at the top of this Privacy Policy. Your use of the Services, or any portion thereof, following the posting of such changes shall constitute your consent to such changes. If we make material changes to this Privacy Policy, we will post a notice of the changes on the Services and will endeavor to provide additional notice to the administrator email address that you provided to us upon registering for the Service.

3. What personal information do we collect?

Information That You Provide Directly:

SurfWisely may collect information that you provide when you use or register for the Services, such as when you:

1. create an account or subscribe to the Services;
2. communicate with SurfWisely through the Services, including to send questions or comments via email, live chat, or phone to SurfWisely customer support;
3. fill out online surveys or questionnaires;
4. opt-in to receive and engage with our email alerts, text message services, and/or other promotional communications;
5. participate in promotions or other marketing activities;
6. otherwise provide information to us, either online or offline.

The personal information that we collect under this policy may include:

• Name;
• Job title;
• School or employer name;
• Personal or professional contact and demographic information;
• Shipping and billing addresses;
• Telephone number; and
• E-mail address.

Information Automatically Collected When You Use the Services

When you access or use our Services, we may also automatically collect information about your visit (collectively, “Online User Activity”). For example, we may collect your computer’s Internet Protocol (“IP”) address and/or your device’s unique identification number, which we use for the support of our internal operations. Other information we and our service providers may collect includes your operating system, access times, browser type and language, and the URL of the website you visited before navigating to our Services. To collect information regarding Online User Activity, we use various technologies, including cookies, clear GIFs, and log files, and we may use third party providers to collect this information on your behalf.

The information regarding Online User Activity we collect automatically may not include personal information, but we may maintain it or associate it with personal information you provide the purposes described in this Privacy Policy.  This helps us to improve our Services and to deliver a more personalized experience, including by storing information about your preferences, recognizing you when you return to the Service, and providing you with better technical support.

Third-Party Integrations in the SurfWisely Subscription Service

The SurfWisely Subscription Service offers third-party integrations that you may choose to enable. For example, to offer single-sign-on (SSO) services or to process payments. These third-party integrations may ask for certain permissions, e.g., to access data or send information to your SurfWisely account, in order to function. If you choose to enable a third-party integration, SurfWisely may collect and/or receive information about your use of the third-party integration.

It is your responsibility to review any third-party integrations you authorize and/or enable. SurfWisely is not responsible for the practices of any third-party integrations offered in connection with the Services. Your use of any third-party integrations is subject to the third parties’ privacy policies, terms of service, and any other related documentation and we encourage you to review the third parties’ privacy policies, terms of service, and related documentation in advance.

4. How do we use your information?

We use personal information collected through our Services for the purposes described in this Privacy Policy or as otherwise disclosed to you on or in connection with our Services. For example, we may use your information to:

• Provide our Services to you, including to operate our websites, maintain customer records, and send you advertising or promotional materials, including information about new products, features and enhancements, special offers, and other events of interest from SurfWisely and our select partners;
• Operate and improve our Services, including by linking or combining your information with other information we get from third parties;
• Send you technical notices, updates, security alerts and support and provide administrative messages, such as changes to this Privacy Policy or our Terms of Service;
• Respond to your comments, questions, and requests and provide customer service;
• Analyze and enhance our communications and strategies (including by identifying when emails sent to you have been received and read);
• Monitor performance of the Services, overall usage of the Services and user retention rates, track how users are engaging with the Subscription Services, identify which website features are least and most utilized, identify problem areas within the websites, and inform design development for future application updates;
• Comply with and enforce as needed applicable legal requirements, industry standards, our policies and our contractual rights; and
• Carry out any other purpose conveyed to you at the time the information was collected.

We may also use or share information in an anonymized or aggregate manner for many purposes such as research, analysis, modeling, marketing, and improvement of our Services.

5. In what situations do we share your personal information?

We do not share your personal information with third parties other than as described in this Privacy Policy or in connection with the Services, including:

• with your consent and at the direction of the Schools, including when we notify you through our Services that the information you provide will be shared in a particular manner and you provide such information;
• with third party vendors, consultants, and other service providers who are working on our behalf and need access to your information to carry out their work for us. For example, to assist us with payment processing, authentication tools, or single-sign-on. We require these entities to maintain the confidentiality, security, and integrity of the personal information they obtain from us, and to process the information in accordance with our instructions, this Privacy Policy and other requirements we deem appropriate;
• when we believe it is necessary or appropriate to: (i) comply with applicable law or legal process or to respond to lawful requests or legal authorities; (ii) protect the rights and property of SurfWisely and our employees, agents, users and other third parties, including to enforce our agreements, policies, and terms of service and protect against fraudulent, abusive, inappropriate, or unlawful use of our Services; and (iii) protect the safety of SurfWisely, our users or any third party; and
• in connection with, or during negotiations of, any merger, sale of company assets, bankruptcy or reorganization, financing or acquisition of all or a portion of our business to another company.

We may also share aggregated information and/or deidentified information that we have collected from you through the Services.

6. What are my information choices?

Regarding Updates and Corrections to Personal Information

If you have registered with our Services, you may at any time review, correct and/or update the contact information we have for you by visiting the account details section of the applicable Service.  You can also request to remove your information from our database by contacting us. If you choose to send us an email, please be sure to include in your message the name of the School you are affiliated with and the email address you used to register so that we can verify your request. We will respond to all requests as soon as possible.

Regarding Cookies

You can decide whether or not to accept cookies through your internets browser’s settings.  Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies.  Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.

Regarding Promotional Communications

You may opt out of receiving promotional emails, text messages, or mail from SurfWisely by declining to receive such communications at the time of registration or at the time you otherwise provide the information to us. If you opt-out, we may still send you transactional or relationship messages, such as emails about your account or our ongoing business relations.

7. How do we keep your information safe?

SurfWisely has established protocols and procedures designed to protect your personal information against loss, misuse and unauthorized access, disclosure, alteration and/or destruction. For example, SurfWisely employs encryption and other security measures where reasonable and appropriate, and strives to provide only those employees performing a legitimate business function with access to users’ personal information. Please be aware, however, that no security measure is ever perfect or impenetrable.

SurfWisely retains your information for as long as reasonably necessary, including (i) for business purposes, including to provide you with our products and services, to support your account, and for the other purposes we use your information as described in this Privacy Policy; and (ii) to comply with our legal obligations, resolve disputes, and enforce our agreements. We may also retain archived or back-up copies of your information for a reasonable period of time.

9. Contact Us

If you have questions or concerns regarding this Privacy Policy, please contact us using the following contact information:

SurfWisely, Inc.
P.O. 56 Nolensville, TN 37135
info@surfwisely.com