Enrichment Core Academy LLC

www.eCoreAcademy.org

PRIVACY POLICY

Last updated: November 4, 2020

Hello! We are eCore Academy (eCore, we, us). Our platform helps high school students (Grades 9-12) understand that there is a better way to learn. No matter where you are on the globe, eCore is committed to helping you leverage the internet to enhance your understanding of STEM-based subjects. At the moment, users can use the platform without any fee, that means no monthly costs or subscriptions fee! Our services are available on all social media platforms and our website at www.eCoreAcademy.org.

The use of our Services and website is intended for students only (up to age 18). This Privacy Policy describes how we collect, hold, use and disclose your personal information.

eCore respects the rights and privacy of all individuals and is committed to complying with the all applicable laws of the United states of America.protect your personal information we hold. We are also committed to complying with any other applicable privacy-related law or regulation related to the data we process.If and when we partner with educational institutions, wewill maintain the confidentiality of all educational records containing the personally identifiable data of any student, teacher or principal in accordance with United States federal and state law and with any applicable policies on data security and privacy maintained by the educational agency(ies) with which eCore contracts including the United States federal and state laws and regulations including the Children's Online Privacy Protection Act of 1998 (“COPPA”) and the California Consumer Privacy Act of 2018 (“CCPA”).

The use of our website may, at times, mandate you to provide certain personal information. Personal information is any information you provide to us that personally identifies you, like your name, email address, or other information which could be reasonably linked to such identifying information by us. We will only collect, use, and share your personal information in accordance with this Privacy Policy. This Privacy Policy applies whether you use eCore through its website, mobile applications, social media platforms or any of our other products or services (now or in future) that link to this Privacy Policy (collectively, the “Service”). Your use of our website, applications, or Services, and any dispute over privacy, is subject to this Policy and our Terms of Service, including its applicable limitations on damages and the resolution of disputes.

This Privacy Policy explains:

The Terms of Service are incorporated by reference into this Policy. This Policy does not apply to websites or services or practices of companies that eCoredoes not own or control, such as third party services you might access throughlinks or other features (e.g., social media buttons) on the Service. These other serviceshave their own privacy policies, and we encourage you to review them before providingthem with personal information.

By accessing or using our website, you are consenting to the collection, use, disclosure and other handling of your information as provided here. If you have any issues or concern about providing information to eCore or having such information displayed on our website or otherwise used in any manner permitted in this Privacy Policy, you should not use our website.

How does eCore collect personal information?
eCore may collect your information via our website, social media pages, and/or smart phone applications (when developed), as well as when you email or call us, or speak to sales and customer service staff.

When providing student, parent, staff or other personal information to us, you must ensure that in doing so, you are complying with your own privacy obligations (including your obligations under your own privacy policy (if any) and any applicable law), By providing such information, you represent to us that you are doing so in a compliant way.

What personal information does eCore collect and how is it used?
eCore collects the types of personal information required to assist with providing eCore’sServices and informing you about them.

On our website, we collect two types of information about the user: (1) information that you may choose to voluntarily provide while using the website; and (2) information collected automatically as a result of your use of the website.The information you provide us may include personal information such as names, student and other identification numbers (if required only), phone numbers, email addresses, and narrative information relating to your experiences, and preferences. In addition, when you send us a message using our website or via email, we may retain the message or email and its contents, your email address, and any information you provide to us such as your name, phone number, your questions or information sought from us, your user experience etc., and the response we send back to you. This is only so that we can respond and manage follow-up email from you or address concerns or questions you may have, measure how effectively we addressed your concerns and to improve our Services or website. When you contact us by any means, your information, such as your email addresses and phone number if provided are not marketed to any person or shared with any person and is limited to addressing your request.

Since our Services are targeted to users below the age of 18 years, we will comply with COPPA. We will not require users to provide more personal information than is reasonably necessary in order to participate in the Service. If and when we partner with any educational institution, such institution will be responsible for obtaining any necessary parental consent under COPPA. If we discover that we have collected information from a user in a manner inconsistent with COPPA, we will take appropriate steps to either delete the information, or immediately seek the parent’s consent for that collection. We do not disclose any personal information about our users to third parties, except to service providers necessary to provide the Service, as required by law, or to protect the security of the Service or other users.

Information collected from child users (including personal information and information collected automatically) is never used or disclosed for third party advertising or for any or third-party behaviorally targeted advertising, and children’s personal information is never sold or rented to anyone, including marketers or advertisers.

Information collected automatically
eCore may use technology for providing our Services, that automatically records or collects certain information from your browser or your devicewhen you use our website, read our emails, or otherwise engage with us. This is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide you eCore’s Services.

If there is information automatically collected that is combined with yourpersonal information, and it will be protected as per this Privacy Policy.The technologies and information we automatically collect include:

Why do we collect personal information?
We generally collect personal information as part of providing you with access to our Services, informing you about them, complying with our contractual and other legal obligations, running promotions and other marketing activities or administering our relationship with you by responding to your enquiries and providing you with information about any of our events and services that may be of interest to you.We will only use your personal information we ask for after obtaining your consent first.

Sharing Your Information
eCore does not and will not sell or release your personal information collected from our website to third parties for any marketing, commercial or promotional purposes. We do not share personal information with third parties except for the limited circumstances set forth in this Privacy Policy.

Parental Consent
If users are below the age of 18, parents’ or a legal guardian’s approval to use eCore’s Services and website must be obtained. Parents and/or legal guardians must consent to their child’s use of our website and Services by completing the ‘Parental Consent’ Form.

If you are the parent or legal guardian of a child who has created an account with usand as per the COPPA, thenyou can contact us through the ‘Contact Us’ form available at https://www.ecoreacademy.org/contact.php, to have your child’s account deleted.

Parents who want copies of their children’s personal information that we may have collected and stored, can contact us through the ‘Contact Us’ form available at https://www.ecoreacademy.org/contact.php. At any time, parentscan refuse to permit us to collect further personal information from theirchild, and can request that we delete the personal information we have collectedfrom their child by contacting us at the email address stated above. Before we can share theinformation with you, or delete it per your request, we willneed to verify your identity, forexample by requiring that you provide acceptableproof of personal identification. We will not entertain requests by third parties unrelated to the child.

How does eCore use your personal information? To whom will it be disclosed?
We may use the personal information we collect and hold for the primary purpose for which it was collected by us, i.e. the purpose specified in a privacy collection statement or any other purpose for which you provide consent.

By providing personal information, you understand that eCore will be using it to:

  1. provide you with our services;
  2. administer our relationship with you;
  3. monitor online activity on our website(s) and/or social media platforms for purposes of improving the eCore website(s);
  4. market, improve and add to eCore’s services (including online);
  5. respond to a serious threat to an individual’s life or to public health or safety;
  6. respond to suspected unlawful activity; or
  7. where required or authorized by law.

eCore limits access to student data to those employees and third party service providers providing services linked to the eCore platform. eCore does not disclose any personally identifiable information of any user to any party outside of eCore’splatform other than those third parties used by eCore to support the eCore platform. The third parties with which eCore contracts are bound by the same data privacy and security requirements to which eCore adheres, according to this Policy.eCore may provide personal informationto third parties authorizedby you to receive personal information held by us.

If a user’s data is to be maintained by eCore for United States federal and/or state reporting, such data shall remain in encrypted format and stored in cloud services based in the United States of America.

Can you remain anonymous or withhold personal information?
Yes. Where practical, you may choose not to identify yourself, deal with us on an anonymous basis or use a pseudonym.

In some instances, if you do not provide us with required personal information, we may not be able to provide you with the requested Service, allow you to participate in promotion activities or obtain the Service you are offering.

As a result, eCore may need to suspend, cancel, decline, and the Services (subject to our terms and conditions and applicable relevant laws).

Will you receive direct marketing?
If you provide us with your personal information (e.g., your email address) and you consent to receiving direct marketing communications from eCore, you authorize us to send you promotional messages and materials related to eCore’s Services and any updates to our teaching schedules, information or updates on teachers etc., unless you submit a later request not to receive direct marketing communications.

eCore’s direct marketing messages and materials will contain a prominent statement (including, for electronic messages, a functional unsubscribe facility) that you may request not to receive direct marketing communications.

If you do not wish to receive marketing or other communications from us, please submit a request not to receive direct marketing communications or use the unsubscribe facility provided in the most recent communication from us or contact us on the details provided.

Even if you do opt out of receiving marketing communications from us, you agree that we may still send you information relevant to the supply of any Services arranged by us.

You may also find links to third party websites via our website or in materials we provide to you. We are not responsible for the content or practices of any third-party website or business. We advise you check the privacy policy and terms and conditions of any third-party website or business before using their services.

Will your information be disclosed overseas?
Currently, eCoredoes not disclose your personal information to any person or entity outside the United States in which you reside. If this needs to change, eCore will inform you prior to any overseas disclosure and will provide the relevant details.

How can you access and correct your personal information?
You have the rights contained in the FERPA, COPPA and the CCPA (if you are a California resident). Make sure to review our policies in compliance with these laws.

To protect personal information held by eCore, you may need to confirm your identity before access to your personal information is granted. It may take a little time to process your application for access and retrieve information from storage (if applicable).

eCore encourages you to update us so that hawse have accurate, current and complete information. You may correct any errors or request that eCore deletes all or some of your personal information. You may also submit a request not to have any further contact from us.

How will eCore make sure your personal information is secure?
eCore limits technical and physical access to student, teacher and principal data when stored or transferred, and it adheres to applicable industry best practices in relation to information security.

Specifically, we will take all reasonable steps to protect the personal information that we hold from misuse, loss, or unauthorized access, including by means of firewalls, password access, secure servers, and encryption of both credit card transactions and all personally identifiable data, whether in transit or at rest.

If you suspect any misuse or loss of, or unauthorized access to, your personal information, please let us know immediately.

If we suspect any misuse or loss of, or unauthorized access to, your personal information we may inform you of that suspicion and take immediate steps to limit any further access to, or distribution of, your personal information. If we determine that the breach is likely to result in serious harm to you and we are unable to prevent the likely risk of serious harm with remedial action, we will take action in accordance with the applicable U.S. laws.

Upon the determination of a breach of security resulting in an unauthorized release of student, teacher or principal data maintained by eCorein violation of applicable United States state or federal law, the terms of the contract between the educational agency to which the data belongs, or the data privacy and security policies of the educational agency to which the data belongs, eCorewill notify such educational agency of the breach in the most expedient way possible and without unreasonable delay.

If we receive unsolicited personal information that we are not permitted to collect under this Privacy Policy, or within the confines of the law, we will destroy or de-identify the unsolicited personal information as soon as practicable if it is lawful and reasonable to do so. We will destroy or de-identify your personal information if we no longer require it to deliver our services as soon as practicable if it is lawful and reasonable to do so.

We endeavor to protect the privacy of your account and other Personal Information at all times and have strong measures in place, but we cannot guarantee complete security. As you would be aware, the transmission of information via the Internet is not completely secure.

Your data is also encrypted at rest on the servers hosted by our cloud services partner who will also ensure compliance with COPPA, and their stringent security measures, including compliance with the following certifications and third-party attestations:

Does eCoreuse “Cookies”?
Yes. When you use eCore’s website(s), products or services, eCoreor our service providers may obtain information using technologies such as cookies, tags, web beacons, and navigational data collection (log files, server logs, and clickstream data) to better understand your user experience. For example, eCoreor our service providers may collect information like the date, time and duration of visits and which webpages are accessed.

This information is generally not linked to your identity, except where it is accessed via links in eCoreemails or where you have identified yourself. We may also collect anonymous data (which is not personal information) relating to your activity on our website (including IP addresses) via cookies. We generally use this information to report statistics, analyze trends, administer our services, diagnose problems and target and improve the quality of our services.

How can you complain about privacy breaches?
If you have a complaint in relation to the collection, use or and disclosure of your personal information, please contact the eCorevia the details provided below. eCorewill review all complaints received and respond to each complainant upon due consideration (which may require further information to be provided).

Will this Privacy Policy change?
eCoremay amend this Privacy Policy from time to time. Amendments will be effective immediately upon notification on this website, so make sure you review this Policy regularly.

Who can you contact about your personal information?
To contact eCoreabout your personal information, concerns or complaints, please reach out to us on ‘Contact Us’ form available at https://www.ecoreacademy.org/contact.php.



Compliance with U.S. laws

This Privacy Policy is in accordance with the U.S. laws including the Children's Online Privacy Protection Act (“COPPA”) and the California Consumer Privacy Act of 2018 (“CCPA”).

COPPA Privacy Policy

Applicability
COPPA applies to personal information collected from children under the age of 13. COPPA applies to eCore for the operation of our websites and online services, when we collectpersonal information directly from you. COPPA only applies to personal information collected through our website from children, including personal information about themselves, their parents, friends, or other persons.

In addition to our Privacy Policy, the policies outlined in this COPPA Privacy Policy supplement the information contained therein and apply to users under the age of 13. In the event any terms of our general Privacy Policy are inconsistent or conflict with this COPPA Privacy Policy, the terms contained in this COPPA Privacy Policy shall prevail.

Teacher or schools’ consent
At this time, we do not partner with any schools or educational institutions, but if we do, we will comply with COPPA. As per the provisions of the COPPA, for any school-based activities,teachers and school administrators can act in lieu of parents and provide consent for the collection of personal information of a student. However, schools have to notify the parents of such student with respect to these activities.

eCore collects limited personal information from students where that student’s school, district, or teacher has provided access to the eCore service, which collects personal information solely for the use and benefit of the learning environment.

Obtaining parent’s consent is mandatory and schools, districts, or teachers must ensure this compliance condition is met.If you are accessing our Service on behalf of a class, school or District, the following provisions also apply:

Personal information
eCore will require users to create an account on the website with details such as email address and enter a password. Such details will be stored on the website. Additional information such as name of school or class, and whether they are a teacher or student, in order to assign the user to the correct user group may be required for the account.

We will not require a user to provide more information than is reasonably necessary in order to participate in the online activity, and we use this personal data for no other purpose than providing the Service. In case users do not wish to share certain information on our website or other platforms, they can choose to do so, however, certain functionalities may not be available without the required information.

Use of Cookies
The use of Cookies is as per our general Privacy Policy.

Changes to this COPPA Privacy Policy
We reserve the right to amend this COPPA Privacy Policy at any time. Please check this page periodically for changes.

Disclosure and Permissions
As per COPPA, we do not disclose personal information collected from users below 13 years of age to third parties other than to persons who provide support for the operations of the Service.We may disclose any and all personal information collected from a user to the parent who registered for the service in connection with such child.

We reserve the right to disclose your personally identifiable information as required by law if believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our website.



Privacy Statement for California Residents

Effective Date: January 1, 2020

Introduction and Scope of this Privacy Statement
This privacy statement supplements our general Privacy Policy and is applicable to you only if you are a California resident. As a California resident, as per the California Consumer Privacy Act of 2018 (“CCPA”), you have the right to know what categories of Personal Information ECore (“ECore,” “we,” “our,” or “us”), collects about you, how and for what purposes we use and share that personal information.

Students’ privacy rights in compliance with FERPA will be complied with and followed, as also stated in our general Privacy Policy.

“Personal Information” as used in this statement, means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. Personal Information includes, but is not limited to, the categories of Personal Information identified below if such information identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular individual or household.

Sale of Personal Information
As stated in the general Privacy Policy, we do not and will not sell or rent, any Personal Information collected through the Services.

Privacy Rights

Right to Know. California residents may request ECoreto disclose the following information about collection and use of their personal information over the past twelve (12) months, provided that such requests are made no more than twice within a twelve (12) month period:

Right to Delete. California residents may request that ECore delete their personal information that we have collected and retained by us or our service providers. However, as per the CCPA, please bear in mind that this right is limited and we may deny such a request if it is necessary for ECore or our service provider to maintain the personal information collected in order to:

Right to No Sale of Personal Information. Even though we do not sell your Personal Information, as per the CCPA, a California resident has the right to opt-out of the sale of their Personal Information by a business subject to the CCPA. In addition, if you are age 16 or younger, thenin compliance with CCPA, ECore will need to have your affirmative authorization in order to sell the Personal Information of a California resident who is of the said age. To reiterate, eCoredoes not sell or rent Personal Information collected through the Services.

Right to Non-Discrimination. eCore does not discriminate against a California resident for exercising any of their CCPA privacy rights.

How to Make a Request under the Right to Know and Right to Deletion - California residents may submit a “Right to Know and Right to Deletion” request to eCore by reaching out to us on the ‘Contact Us’ form available at https://www.ecoreacademy.org/contact.php.

We will not require a California resident to set up an account in order to make a request or receive the requested information. In order to respond to a request, however, we must be able to reasonably verify, understand and fulfill the request. We will not be able to respond to the request if we are unable to verify identity or the authority to make the request. In conducting verification, we generally will use personal information previously collected by us or require you to submit necessary personal identification documentation as described in our general Privacy Policy. We do not entertain requests made on behalf of another individual except a user’s parents. In responding to requests, we may limit the information provided for privacy and security reasons, as permitted by law.

Our goal is to respond to requests within thirty (30) days. If we need more time, we will request another thirty (30) days.

Changes to this California Privacy Statement
We may update this Privacy Statement from time to time in the same way that we update our general Privacy Policy.

Contact Information
If you have any questions or comments about this statement or your rights under California law, please contact us at https://www.ecoreacademy.org/contact.php.