Last updated October 16, 2020
PIVOT LEARNING understands and shares your concerns about security and privacy. All information we collect is confidential. Please review the following information to understand how the information you provide will be treated.
PIVOT LEARNING will never sell, trade, or rent the e-mail addresses or personal information of any site visitor or customer to any third party, nor will we share this information with any third party, except to the extent necessary to fulfill an order or when the outside party is strictly acting on our behalf with no independent right to use the information we provide. We may provide statistics about our customers, sales, traffic patterns, and related site information to certain reputable third-party vendors, but these statistics will not include any identifying personal information. We will disclose personal information only when we are required by law to do so.
Our order form collects customer contact information such as name, address, e-mail address, telephone number, and credit card financial information that is needed to process and bill an order. The contact information is used to send information about orders and our company to our customers, and to fulfill orders and get in touch with customers if necessary for customer service.
We also ask you for personal information on our Contact, Site Visit Feedback, and Permissions Request forms.
Privacy for CA Residents
Information We Collect
Our Services collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, our Services have collected the following categories of personal information from PIVOT LEARNING visitors and users within the last twelve (12) months:
|A. Identifiers||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.||Yes|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))||A name, signature, address, telephone number, employment, bank account number, credit card number, debit card number, or any other financial information. Some personal information included in this category may overlap with other categories.||Yes|
|C. Protected classification characteristics under California or federal law||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||No|
|D. Commercial information||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies||Yes|
|E. Biometric information||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||No|
|F. Internet or other similar network activity||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||Yes|
|G. Geolocation data||Physical location or movements.||No|
|H. Sensory data||Audio, electronic, visual, thermal, olfactory, or similar information.||No|
|I. Professional or employment-related information||Current or past job history or performance evaluations.||No|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||No|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||No|
Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, such as:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
- Directly from you. For example, when you complete an online form and when you register for and use our Services.
- Indirectly from you. For example, from observing your actions on our website.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our Services or to access information on our site, such as a webinar, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase our Services, we will use that information to process your payment and facilitate delivery of the Services. We may also save your information to facilitate new product orders or process refunds.
- To provide, support, personalize, and develop our Services.
- To create, maintain, customize, and secure your account with us.
- To process your requests, purchases, transactions, and payments and prevent transactional fraud.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To personalize your experience of our Services and to deliver content and product and service offerings relevant to your needs, experiences and interests, including recommended content or targeted offers through our website, third-party sites, and via email or text message (with your consent, where required by law).
- To help maintain the safety, security, and integrity of our Services, databases and other technology assets, and business.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of PIVOT LEARNING’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by PIVOT LEARNING about users of our Services is among the assets transferred.
PIVOT LEARNING will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
PIVOT LEARNING may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, PIVOT LEARNING has disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category D: Commercial information.
Category F: Internet or other similar network activity.
We disclose your personal information for a business purpose to the following categories of third parties:
- Service providers
Sales of Personal Information
In the preceding twelve (12) months, PIVOT LEARNING has not sold personal information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that PIVOT LEARNING disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that PIVOT LEARNING delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either calling us at 510.250.2543 or emailing us at firstname.lastname@example.org.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We will confirm receipt of your request within 10 days and provide information about how we will process your request, including our verification process. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and the extension period in writing, which may be up to an additional forty-five (45) days.
If you have an account with us, we will deliver our written response to the email address associated with that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
- However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
Changes to Our Privacy Notice
PIVOT LEARNING reserves the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will post the updated Privacy Notice on our website and update the Privacy Notice’s revision date. If we make material changes to this Privacy Notice, we will notify you here, by email (sent to the email address specified in your account if you have one) or by means of a notice on our home page. Your continued use of our Services following the posting of changes constitutes your acceptance of such changes.
1300 Clay St. Suite 600
Oakland, CA 94612
If we have a question about an order you’ve placed, we may contact you by e-mail; however, we never send unsolicited e-mail such as newsletters and promotional information to our customers. If you would like to join our promotional mailing list, you can register for it on our Contact page. Recipients of our promotional information are always provided with a way to opt out of receiving future mailings.
Although we make every attempt to maintain the confidentiality of the personal information we collect online, no data transmission over the Internet can be guaranteed to be 100% secure, and we cannot guarantee that the personal information you submit to us will be free from unauthorized third-party intrusion. You therefore understand and agree that all information you submit to PIVOT LEARNING is done so at your own risk.
Contact PIVOT LEARNING
If you have any questions about this privacy statement or this website, contact us.