Effective Date of Current Policy: 11.27.19
The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with LMT and the requirements of applicable law. Some of the ways that LMT may collect Personal Information include:
- You may provide your name and email address to LMT through interacting with the Services, registering for an account, participating in surveys, and requesting Services or information.
- As you navigate the Services, your IP address, login duration, browser, and other session details may also be collected through cookies and similar technologies as described in 3.2 below.
We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.
3.1 USE OF INFORMATION
We acquire, hold, and process data added by you for the sole purpose of effectively providing the service, which includes:
- To Provide Products, Services, or Information Requested. LMT may use information about you to fulfill requests for products, services, or general information, including:
- Generally manage Individual information and accounts;
- Respond to questions, comments, and other requests;
- Provide access to certain areas, functionalities, and features of LMT’s Services;
- Contact you to answer requests for customer support or technical support;
- Administrative Purposes. LMT may use Personal Information about you for its administrative purposes, including to:
- Ensure internal quality control;
- Verify Individual identity;
- Communicate about Individual accounts and activities on LMT’s Services and systems, and, in LMT’s discretion, changes to any LMT policy;
- Send email to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance;
- Process payment for products or services purchased;
- Process applications and transactions;
- Prevent potentially prohibited or illegal activities;
- Enforce our Terms.
- Other Uses. LMT may use Personal Information for which we have a legitimate interest, such as research, network and information security, disclosure to affiliated organizations for administrative tasks, fraud prevention, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
3.2 COOKIES, LOCAL STORAGE, and ANALYTICS
- Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
- Local Storage. We store information about the login session to keep your information current while you are logged in
- Analytics. We may also use Google Analytics to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
Our uses of such Technologies fall into the following general categories:
If you would like to opt-out of the Technologies we employ on our Sites, Services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.
3.3 THIRD-PARTY WEBSITES
The Services may contain links to other websites and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us, and LMT does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
3.4 THIRD PARTY DATA PROCESSING
We may process payments through our Services. When you make purchases through the Services, we process your payments through a Third-Party application. The Third-Party application may collect certain financial information from you to process a payment on behalf of LMT, including your name, email address, address and other billing information.
4.0 INFORMATION SHARING
- Sub-processors. We may share any information we receive with qualified service providers, whom we entrust Personal Information for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Services.
- Business Partners. LMT may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. LMT may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with LMT.
- Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce LMT’s policies or contracts; (v) to collect amounts owed to LMT; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
4.1 INFORMATION DISCLOSURE
LMT may be required to disclose personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. In cases of onward transfer to non-agent third parties of data of EU and Swiss individuals received pursuant to the Privacy Shield Principles, Learning Machine Technologies, Inc. is liable unless we can prove we were not a party giving rise to the damages.
LMT will only disclose your personal information within your organization through LMT Services and with recipients you have chosen to send this information to through digital records issued with LMT Services.
If we ever were to engage in any onward transfers of your data with any third parties for a purpose other than which it was originally collected or subsequently authorized, we would provide you with an opt-out choice to limit the use and disclosure of your personal data.
4.2 INTERNATIONAL DATA TRANSFERS
You agree that, unless otherwise specified, all Personal Information collected by LMT may be transferred, Processed, and stored anywhere in the world, including but not limited to, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers in order to provide the services.
5. OPT OUT
You have the right to object to and opt out of certain uses and disclosures of your Personal Information. Where you have consented to Learning Machine’s processing of your Personal Information, you may withdraw that consent at any time and opt-out to further processing by contacting email@example.com.
5.2 EMAIL AND TELEPHONE COMMUNICATIONS
We maintain telephone “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.
5.3 “DO NOT TRACK”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
6. RIGHTS OF ACCESS, RECTIFICATION, ERASURE, AND RESTRICTION
Although LMT makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which LMT is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question, where the request is manifestly unfounded or excessive, or where it is commercially proprietary. If LMT determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, LMT will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
7. DATA RETENTION
8. SECURITY OF YOUR INFORMATION
By using the Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we will attempt to notify you electronically by posting a notice on the Services or sending an e-mail to you. You may have a legal right to receive this notice in writing.
9. EU-US & SWISS-US PRIVACY SHIELD
Learning Machine Technologies, Inc. requires our sub-processors to comply with the terms of Privacy Shield. You can view that list below.
|Amazon Web Services||Cloud Infrastructure|
|Matamo||Login Session Monitoring|
Learning Machine Technologies, Inc. has further committed to refer unresolved privacy complaints under the Privacy Shield to an independent dispute resolution mechanism, the BBB EU Privacy Shield. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Learning Machine, please visit the BBB EU Privacy Shield web site for more information and to file a complaint.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1.
Learning Machine Technologies, Inc. is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
Learning Machine’s commitment to GDPR regulations can be found http://learningmachine.com/gdpr
11. CHILDREN’S POLICY
The Services are not directed to children under 13 (and in certain jurisdictions under the age of 16) years of age, and LMT does not knowingly collect Personally Identifiable Information from children under 13 (and in certain jurisdictions under the age of 16) years of age. If we learn that we have collected any Personal Information from children under 13 (and in certain jurisdictions under the age of 16), we will promptly take steps to delete such information.
12. REDRESS/COMPLIANCE AND ACCOUNTABILITY
13. OTHER RIGHTS AND INFORMATION
- New Uses of Personal Information. Additionally, before we use or share Personal Information for any new purpose not originally disclosed or authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt-out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, LMT will endeavor to comply with the law or contract.
13.2 CALIFORNIA PRIVACY RIGHTS
The following capitalized terms shall have the meanings herein as set forth below.
- “Agent” means any Third Party that Processes Personal Information pursuant to the instructions of, and solely for, LMT or to which LMT discloses Personal Information for use on its behalf.
- “Personal Information” is any information relating to an identified or identifiable natural person (“Individual”).
- “Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
- “Third Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, LMT or LMT’s Agents.
15. REVISION HISTORY
- November 27, 2019
- September 01, 2018