PRIVACY POLICY

Last Modified: September 25, 2019.

Protecting your private information is our priority. This privacy policy (“Privacy Policy”) applies to LI2EI, LLC (hereinafter, variously “Company”, “we”, “us”, or “our”), and our website www.li2ei.com, any sites Company may have now or in the future and its software-as-a-service solution and mobile application that enables educators, parents and students to assist with classroom management, differentiation, and curriculum, while encouraging positive growth in the student through screen time (collectively, the “Services”), and outlines our principles for collecting, using and protecting information that we maintain about any person whose personal data is being collected, held or processed by us including without limitation customers and/or site visitors (hereinafter the “Individual(s)” or “you”).

By using the Services in any manner, you indicate to the Company that you have read and accept our Privacy Policy and consent to the data practices described in this Privacy Policy. If you do not accept this Privacy Policy or do not meet or comply with the provisions set forth herein, then you may not use the Services. If required by applicable law, we will seek your express consent to process personal data (i) provided by you and/or (ii) collected during your use of the Services. Any consent shall be entirely voluntary. In the event you do not provide consent to use or process your personal data, then you may not access and/or use the Services.

INFORMATION WE COLLECT

When you use the Services, you may provide the Company with two main types of information: (1) personally identifiable information that you knowingly choose to disclose, which is collected on an individual basis, and (2) general user information that does not contain personally identifiable information, which is collected on an aggregate basis as you browse and use the Services. We collect information from you when you (a) use and/or access the Services, (b) register an account and/or subscribe to the Company, (c) open and/or respond to our emails, (d) contact the Company, (e) visit any page online that displays our content, (f) make purchases through the Services, and/or (g) provide information to any of our customers, partners, and/or other users.

Personally Identifiable Information You Choose to Provide

We may ask for certain personal information from you for the purpose of providing to you content and/or services that you request. We collect personal information such as your: (i) personal and/or business contact information (including name, telephone number, email and address, and business website address); (ii) financial information (such as checking account information, credit card number, expiration date, verification number, and billing address); (iii) username and password; (iv) demographic information (including age, birthdate and gender); (v) location information (such as geographic location of the device you are using); (vi) preferences and behavior (such as record of comments, responses and questions asked); (vii) school account information, if applicable, and/or (viii) academic performance related information. Once you register, you have opted in to receive electronic communications from the Company. Please note that some of the foregoing information will only be asked when an adult is registering an account. The company may also provide you with the opportunity to participate in surveys through the Services. If you participate, we will request certain personally identifiable information. Participation in surveys is completely voluntary and you therefore have a choice whether to disclose such information.

Credit Card and Payment Information. Please note that when your bank account information or credit card information is transmitted via the Services, it will be protected by encryption technology used by our third party payment processor, ‘Stripe.’ The Company does not store credit card details and instead utilizes ‘Stripe’ to process payments made to us. In connection with the processing of such payments, we do not retain any personally identifiable information or any financial information such as credit card numbers. Rather, all such information is provided directly to our third party payment processor, who use of your personal information is governed by their privacy policy.

Additional Information for School Accounts

If you have access to the Services through an account for schools, school districts, licensed childcare facilities or other licensed educational institutions or programs (each “Educational Account”), additional privacy protections apply because your Educational Account may provide us with personally identifiable information of students (Student Data) as defined by the Family Educational Rights and Privacy Act 20 U.S. C. § 1232g and its implementing regulations (34 CRF Part 99) (collectively, “FERPA”). We will only access, collect, record, organize, use or disclose Student Data collected through the services as described in any relevant agreement with the applicable Educational Account and this Privacy Policy.

Information We Collect Automatically

When you access and/or use the Services, we may automatically collect information about you, including:

Cookies: In an effort to be transparent with our data collection practice and the technologies we use to provide the Services, the following explains how we use Cookies. We use Cookies and web log files for the primary purpose of providing the functionality of the website itself. A “Cookie” is a tiny data file that resides on your computer, mobile phone, or other device, and allows the Company to recognize you as a user when you return to our website using the same device and web browser and enables the Company to collect information about how you use our Services. Information gathered through Cookies may include the date and time of visits, the pages viewed, and time spent at using the Service. If you do not agree to our use of Cookies, you should set your browser settings accordingly or not use the Services. the Company uses Cookies and web log files for the following, which may include without limitation (i) to track usage and trends, (ii) to improve the quality of the Services, (iii) to customize your experience and/or (iv) to compile anonymous, aggregated information that allow us to understand how our Services are used. Cookies are categorized by how long they are stored and their function. The Cookies the Company uses are as follows: Session Cookies: Session Cookies are temporary and deleted from your computer when you close your web browser. They allow the Company to link the actions of a user while using the Services.

Performance Cookies: Performance Cookies collect anonymous data for statistical purposes on how users use the Services, they don’t contain personal information and are used to improve the user experience.

Strictly Necessary Cookies: Strictly necessary Cookies are essential to navigate around the Services and to use its features.

Persistent Cookies: Persistent Cookies remain on a visitor’s device for a set period of time specified in the Cookie. They are activated each time the visitor visits the Services that created that particular Cookie.

You may remove or block Cookies using the settings in your browser, but in some cases that may impact your ability to use our Services and/or user experience while using the Services. By accessing or using the Services, you consent to the placement of Cookies on your device as described in this Privacy Policy. If you prefer not to receive Cookies through the Services, you may control how your browser responds to Cookies by adjusting the privacy and security settings of your web browser. Please note, in some cases that may impact your ability to use the Services and/or user experience while using the Services.

Device Data: We use device data, which is information concerning a device you use to access, use, and/or interact with the Services, such as operating system type and/or mobile device model, browser type, domain, and other system settings, the language your system uses and the country and time zone of your device, geo-location, unique device identifier and/or other device identifier, mobile phone carrier identification, and device software platform and firmware information.

Aggregate: We may collect non-identifying and statistical information about the use of our Services, such as how many visitors visit a specific page, how long they stay on that page and which links, if any, they click on, system configuration information and/or other interactions with the Services. This information represents a generic overview of our users, including their collective habits. Information collected in the aggregate is not associated with you as an individual.

Analytics: We use analytic software to gather statistics and usage trends for product and service improvement purposes. The Service may record data from your phone, tablet, or computer such as how frequently you use the Service, what actions you take and performance data.

Other Tracking Technologies: We may supplement information you provide to us with information from other sources, such as information to validate and/or update your address, payment card and/or other demographic information. This information is used to maintain the accuracy of information on our Services and for internal analysis. We may also use clear gifs, pixel tags and web beacons, which are tiny graphic images placed on website pages and/or in our emails that allow us to determine whether you have performed specific actions and are further used to track online movements of our users. In contrast to Cookies, which are stored on your computer’s hard drive, clear gifs are embedded invisibly on web pages. We do not tie the information gathered by clear gifs to your personally identifiable information.

Third Party Services: To support the services we provide to you, we may use services hosted by third parties that may use Cookies and various tracking technologies and may collect information sent by a browser as part of a web page request, including ‘Internet Protocol’ addresses, browser software, and/or clickstream patterns. If such third-party services collect information, they do so anonymously without identifying individual visitors. However, we may link the information we record using tracking technology to personal information we collect.

HOW WE USE INFORMATION

General Use

We use information collected as described in this Privacy Policy to provide you with the Services and/or information and/or content that you have requested, and, in some cases, to contact you about our products, features and/or other services. We also use the information collected to take the following actions:

The information collected in the aggregate enables us to better understand your use of the Services and to enhance your enjoyment. We may use financial information to enroll you in one of our accounts and/or other related services in which you elect to participate. If you use the Services, you agree to receive certain communications from us including but not limited to the following:

Special Offers, Newsletters and Updates. We will occasionally send you information on products, special deals, promotions and newsletters. Out of respect for your privacy, you may elect not to receive these types of communications by contacting us at contact@li2ei.com.

Customer Service. Based upon the personally identifiable information you provide us, we will communicate with you in response to your inquiries and reviews, to provide the services you request and to manage your account. We will communicate with you by email, through the Services, or telephone, as you may elect. You can reach the Company by email at contact@li2ei.com or phone at 626-532-3329.

Parties with whom we may share your information:

Service Providers. We may share your personally identifiable information as well as information from tools like Cookies, log files, and device identifiers and location data (such as usage data, referring/exit pages and URLs, platform types, number of clicks, etc.), with employees, contractors, third-party providers and/or agents that help us provide the Services to you (the "Service Providers"). Our Service Providers will be given access to your information as is reasonably necessary to provide the Services. We take the privacy of our users very seriously, and we do not sell, rent, and/or otherwise provide your personally identifiable information to third parties for marketing purposes. We will not share your personally identifiable information in ways unrelated to those described in this Privacy Policy without providing you with an opportunity to opt out of such use or otherwise prohibit such unrelated use. Certain Service Providers will automatically collect non-identifying information about your use of the Services and the Company shall not have any liability related thereto. Notwithstanding the foregoing, the Company reserves the right to sell non-identifying information and data (such as gender, age group, cities, states, rewards, content selected, etc.), collected in the aggregate, to outside third parties.

Compliance with Laws. The Company will not disclose your personal information to third parties except as set forth in this Privacy Policy and in the following circumstances: (i) to investigate and defend Company members against any third party claims and/or allegations and/or otherwise to protect the Company from liability, (ii) to investigate, prevent and/or take action regarding suspected and/or actual illegal activities, (iii) to assist government enforcement agencies, respond to a legal process and/or comply with the law, (iv) to exercise or protect the rights, property and/or personal safety of the users of the Services and/or (v) to protect the security and/or integrity of the Service. Service Providers may share your personal identifiable information as well as non-identifying information to comply with legal obligations. For example, in connection with an unauthorized, fraudulent, or illegal payment, a third-party Service Provider may share any information related to such activity with the appropriate financial institution, regulatory authority, or law enforcement agency consistent with its legal obligations. This information may include information about you and the payment transactions made. Notwithstanding anything herein to the contrary, the Company is not responsible for any losses, whether direct or indirect, that you may incur as a result of the Company or the Service Provider’s response to a request for disclosure of personal information or non-identifying information required by law.

Business Transfer. If we sell or otherwise transfer part or all of the Company or our assets to another organization (e.g., in the course of a transaction such as a merger, acquisition, bankruptcy, dissolution, liquidation, etc.), your information such as name and email address, user content and/or any other information collected through the Services may be among the items sold and/or transferred.

Sharing with Authorized Parties. We may share information about a student’s use of the Services with schools, teachers and/or parents in order to provide the Services, curriculum and reward details needed to assist with classroom management, differentiation, and curriculum.

INFORMATION CHOICES

Your Information Choices

We respect your privacy and give you an opportunity to opt out of receiving announcements of certain information. Although we think that you benefit from a more personalized experience when we know more about you and what you like, you can limit the information you provide to the Company, and you can limit the communications that the Company sends to you. If you visit the Services and volunteer personally identifiable information, you can opt out of receiving notifications, such as newsletters, and you may review, modify, update, and/or delete such personally identifiable information by contacting and/or by changing your preferences on the Service. Please be aware that we may still email you non-commercial emails related to your account and your transactions through the Services.

Your California Privacy Rights

Under California Consumer Privacy Act (“CCPA”), California residents are entitled to receive the right to access and obtain a copy of your personal information. You may write us and ask for records of any and all personal information. The CCPA requires businesses to disclose (1) the categories of personal information the business collected about Individuals, (2) the categories of sources from which personal information is collected, (3) the business or commercial purpose for collecting or selling personal information, (4) the categories of third parties with whom the business shares personal information, and (5) the specific pieces of personal information the business has collected about the Individual. To obtain such information from the Company, please email your request to contact@li2ei.com and we will provide a list of categories of personal information disclosed within thirty (30) days of receiving such a request. This request may be made no more than once per calendar year. We reserve the right not to respond to requests submitted in ways other than those specified above. The following exceptions may prevail with respect to fulfillment of data access requests: (a) the Company may not provide personal data to you, if management determines that we cannot identify you in our systems because the data we have has been de-identified to the extent that identification is not possible; and/or (b) the Company may not provide personal data to you, if you are involved in a civil or criminal proceeding with the Company.

SERVICE ELIGIBILITY AND CHANGES

Children and Minors. If you are under eighteen (18), you may use the Services only with the involvement of a parent or guardian. Other than in the places and for the purposes explicitly disclosed in this Privacy Policy and/or the Children’s Privacy Disclosure, we do not knowingly collect personal information from children under the age of thirteen (13) without the consent of the child's parent or guardian. For more information, please see our Children's Privacy Disclosure https://app.li2ei.com/children_privacy. If we learn that we have collected personal information from a child under the age of thirteen (13) without parental consent, we will delete such information as quickly as possible. If you believe that a child under the age of thirteen (13) may have provided us personal information without the proper consent, please contact us at contact@li2ei.com.

Changes to Privacy Policy. In general, changes will be made to this Privacy Policy to address new or modified laws and/or new or modified business procedures. However, we may update this Privacy Policy at any time, with or without advance notice, so please review it periodically. We will update the ‘Last Modified’ date above and may provide you additional forms of notice of modifications and/or updates as appropriate under the circumstances. You can determine when this Privacy Policy was last revised by referring to the date it was “Last Modified” above. Your continued use of the Services after any modification to this Privacy Policy will constitute your acceptance of such modifications and/or updates.

SECURITY

We use commercially reasonable efforts to secure your personal information from unauthorized access to and/or unauthorized alteration, disclosure and/or destruction of information we hold. We have adopted appropriate physical, electronic and managerial procedures to safeguard and secure the personal information we process. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. Your account is protected by password for your privacy and security. We periodically review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems. Because the internet is not a completely secure environment, the Company cannot warrant the security of any information you transmit to the Company or guarantee that information on the Services may not be accessed, disclosed, altered, and/or destroyed by breach of any of our physical, technical and/or managerial safeguards. Please do your part to help the Company. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to emails between you and the Company, at all times. Please limit your access to your computer and/or mobile device and/or browser by signing off after you have finished accessing your account. We are not responsible for the functionality, privacy and/or security measures of any other organization.

DATA RETENTION

We will retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use and/or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. Following termination and/or deactivation of your account, we may retain information (including without limitation your personally identifiable information) for a commercially reasonable time for backup, archival, audit purposes, and/or to comply with legal obligations, resolve disputes and enforce agreements. In some cases, if you choose not to provide the Company with requested information, you may not be able to use and/or access all of the Services. You can request further details of retention periods for different aspects of your personal data by contacting us. Notwithstanding the foregoing, the Company reserves the right to retain your personal data indefinitely.

DATA TRANSFERS

Please be aware that the Services are subject to United States laws, including those governing privacy and security of your information. By using the Services, you agree and consent (and represent that you have the authority to provide such consent) to the information collection, use and sharing practices described in this Privacy Policy and understand that the laws of the United States and other countries and territories related to the foregoing may differ from those of other countries and may not be as protective as the laws in the country where you reside. Regardless of the laws in place in such countries, we will treat the privacy of your information in accordance with this Privacy Policy.

OTHER WEB SITES AND SERVICES

We are not responsible for the practices employed by any websites and/or services linked to and/or from the Services, including the information and/or content contained therein. Please remember that when you use a link to go from the Services to another website and/or service, our Privacy Policy does not apply to such third-party websites and/or services. Your browsing and interaction on any third-party website and/or service, including those that have a link on the Service, are subject to such third party's own rules and policies. In addition, you agree that we are not responsible and do not have control over any third parties that you authorize to access your personal information. If you are using a third-party website and/or service and you allow them to access your personal information, you do so at your own risk.

LANGUAGE

The governing language of this Privacy Policy is English, which shall prevail over any other languages used in any translated document.

HOW TO CONTACT US

If you have questions and/or comments about this Privacy Policy, please email us at contact@li2ei.com.

Because email communication is not always secure, please do not include credit card or other sensitive personal information in your emails to us.