- Effective Date: 04/28/2021
If you are under the age of 18, you have certain additional rights with respect to the removal of Content which you may provide to the Sites. These rights are set forth in Section 14 below.
- Categories of Personal Information We Collect
- Personal Information in Publically Accessible Areas
- How We Collect Personally Identifying Information
- How We Collect and Use Information About Your Use of the Sites
- How We Collect and Use Personal Financial Information
- How We Use Personal Information
- When We Share Personal Information with Third Parties Who May Offer Products or Services that May be - of Value to You.
- When We Share Personal Information with Partners in Education and Employment
- When We Share Personal Information with Contractors and Service Providers
- Disclosures of Personal Information in Litigation, Investigations or Enforcement Actions or for Security Reasons
- Disclosures in Conjunction with a Change in Control or Similar Event.
- Your Access Rights
- Children’s Privacy
- Information Security and Storage
- Rights to Opt Out
- California Residents
- EU Residents
- International Data Transfers
Categories of Personal Information We Collect.
There are three categories of personal information we collect from you and that we have collected in the last twelve months:
- Personal Information You Provide Us: this is information that is identifiable to you, as an individual, which you may provide to the Sites if you register on the Sites and engage in any Site activities. It may include:
Identifiers, such as name, number of children in household, age of children, housing type, transportation, hobbies, and employment), contact details (e.g., phone number, email address, postal address), and account details (e.g., username and password);
- Financial or health insurance information such as household income before taxes;
- Credit card or debit card information;
- Psychometric and career interest information;
- Educational and career history (including e.g., location of jobs, job types and salary information); and
- Demographics, including some protected classification characteristics under California or federal law, such as age, gender, marital status, ethnicity, and primary language.
- Information we collect about your use of the sites: this is information commonly collected by many websites to track website usage. It may include:
- Identifiers, such as computer, server, and client IP addresses and usernames;
- Internet or other electronic network activity information, such as browser versions, pages most visited, duration and time of visit, as well as standard fields from our web log reporting software; and
- Geolocation information.
- Information from Third Parties: We may also collect Personal Information about you from third parties to perform certain functions such as collections activities or to customize our marketing efforts.
Personal Information in Publically Accessible Areas.
Some interactive portions of our Sites are open and visible to the larger public and/or people and entities engaged in providing or supporting Sokanu products and services. If you include personally identifying information in materials you contribute to the Sites, via postings, chat rooms, or otherwise, that personal information will be available to members of the larger public. We therefore strongly encourage you not to include personally identifying information in your interactions in public forums made available through the Sites, such as in postings or in chat rooms, or in your Username.
How We Collect Personal Information.
We collect Personal Information that you voluntarily provide to us. For example, when you register as a User on the Sites in order to participate in the Sites activities, we ask you for personal information such as your name, email address, and telephone number. We may also collect this information if you contact us requesting information, participate in or provide feedback on the Sites or Site activities, or forward information from the Sites to internet addresses outside of the Sites.
How We Collect and Use Information About Your Use of the Sites.
We use common tracking tools such as cookies, clear GIFs (also referred to as web beacons or pixel tags), device identifiers or IP addresses to collect information about your use of the Sites. We also use third-party analytics services, including Google Analytics, to analyze traffic and optimize performance; these services may also place cookies on your device. These tools, described in more detail below, are associated with standard internet protocols and are commonly implemented on web sites. The information collected through these tools is primarily used for aggregate, statistical reporting and stored in log files. Log files are simply transaction records that web servers maintain and record information, such as: service provider IP addresses, browser versions, referring websites, search terms used, average number of pages requested, average duration of visit, and/or total visitor traffic.
- Cookies are small files web sites place on your hard drive that allow sites to identify you. For example, if you allow a site to remember your login name or password, the site places a cookie on your computer. Cookies cannot read any other information on your hard drive. If you do not wish to receive cookies or want to be notified of when they are placed, your browser may permit you to do so.
- GIFs can tell us whether you have visited a Web page or received or opened a message we send to you.
- An IP address is a number that's automatically assigned to your computer by your Internet service provider whenever you're on the Internet. In addition to logging your IP Address, our server may also record the referring page that linked you to us (e.g., another web site or a search engine); the pages you visit and how long you stay on the Sites; and other Web usage activity and data. In some cases, your IP address stays the same from browser session to browser session; but if you use a consumer internet access provider, your IP address probably varies from session to session.
The information we collect about your use of the Sites may be used to measure the Sites’ traffic, help us to evaluate and improve the Sites, provide data points for marketing and business analysis, and better serve our Users. It is in our legitimate interests to evaluate and improve the Sites so that we may better serve our Users. We may share this information with third parties, but only in an aggregate statistical form that includes no personally identifying information. If we combine information about your use of the Sites with Personal Information, through data mapping or otherwise, the combined information will be treated as Personal Information.
How We Collect and Use Personal Financial Information.
We collect Personal Financial Information you provide only when you are purchasing products or services from Sokanu, or involved in other financial transactions with Sokanu, and we use this information only in connection with your purchases and other financial transactions. We collect this information so we can comply with our contractual obligations to you or interact with you in furtherance of initiating a contractual arrangement (e.g., if you are applying to enroll) and so that we can comply with our legal obligations. Personal Financial Information is retained by Sokanu as required by law and its internal business practices. If you have no outstanding, pending, or contractual financial obligation to Sokanu, you may ask that we delete your financial information and we will do so subject to legal, regulatory, licensing and accreditation obligations.
How We Use Personal Information.
We use your Personal Information in multiple ways, including to:
- Fulfill or meet the reason for which the information is provided (e.g., to provide career guidance).
- Deliver products and perform services you purchase. This is so we can comply with our contractual obligations to you or engage in pre-contractual measures (e.g., if you apply to enroll in one of our programs or our partners’ programs).
- Respond to your requests for information. It is in our legitimate interests to respond to your requests for information.
- Contact you regarding products and services in which we believe you may be interested. It is in our legitimate interest to provide relevant and interesting advertising messages. Where necessary, we will obtain your consent before sending such marketing messages.
- Notify you about community events and activities. It is in our legitimate interests to notify you about events and activities that may be of interest to you.
- Ask you questions about your interests and your experience on the Sites. It is in our legitimate interests to learn more about your experience with the Sites.
- To perform proactive outreach to encourage and engage you in your studies and career development.
- To offer savings opportunities and/or promotional items only available to Sokanu customers.
When We Share Personal Information with Third Parties Who May Offer Products or Services that May be of Value to You.
We may provide your Personal Information to third parties who offer products or services we believe may be of value to you; such third parties are only allowed to use your Personal Information to contact you regarding those products or services and you are able to “opt out” from receiving such contacts at any time through the “opt out” procedures of those third parties. (See also Section 18 (“Rights to Opt Out”) below).
When We Share Personal Information with Partners in Education and Employment Who May Also offer Services.
Sokanu often collaborates with school districts, individual schools, colleges and universities, vocational schools, organizations like the Job Corps, job search and recruiting services, career development services, and other private educational, education-related, or employment related programs (each an “Educational or Employment Partner”) to provide a broad range of educational or career-related programs responsive to different types of students’ and job seekers’ requirements. We may share Personal Information, including Personally Identifying Information and Personal Financial Information of students, job seekers, and other Sokanu users that we believe may be interested in these collaborative or partnership educational or employment programs or when they are enrolled in these programs, with the associated Educational or Employment Partner.
When We Share Personal Information with Contractors, Service Providers and Others.
We may use third parties (including contractors, business partners and service providers) to help us with certain aspects of our operations and this may require disclosure of your Personal Information to them. For example, we use third party financial institutions to help us process payments and we may use third party agencies to help us with debt collection. We may also use third parties to help us to operate the Sites, deliver products and provide services. We expect these third parties to use your Personal Information only as necessary to perform the services they are asked to perform.
Disclosures of Personal Information in Litigation, Investigations or Enforcement Actions or for Security Reasons.
We may disclose your Personal Information when compelled or requested to do so by government or law enforcement authorities or when otherwise required or permitted by law, such as to respond to court orders and subpoenas or regulatory agency requests. We also may disclose Personal Information when we have reason to believe that someone is causing or threatening to cause injury to, or interfering or threatening to interfere with, the rights or property interests of Sokanu or its affiliates (or their respective employees, agents, consultants, contractors or representatives), Sokanu Site Users, Sokanu business partners (including Education Partners and service providers), or other persons or entities that could be harmed by such activities.
Disclosures to Affiliated Companies and to Companies in Conjunction with a Change in Control or Similar Event.
Sokanu may share your Personal Information among its subsidiaries and affiliates, primarily for business and operational purposes. In addition, if Sokanu undergoes or contemplates undergoing a business transition, such as a merger or acquisition by another company, or a sale of all or a substantial portion of its assets, your Personal Information may be shared or among the assets transferred or subject to new ownership. Changes in the terms governing the collection, storage or use of any third party successor in interest or transferee of your Personal Information, if any, will be communicated to you by Sokanu or such third party via email, the applicable website, or a comparable means notification.
Your Access Rights.
You may review and correct the Personally Identifying Information that is retained by Sokanu in your account after you login. You may review and correct the Personal Financial Information that is retained by Sokanu in your account by contacting Sokanu at firstname.lastname@example.org.
The Sites do not knowingly collect information from (a) children under the age of 13 and does not offer products, services or activities targeted at children under the age of 13, or (b) individuals older than 13 but under the age of legal majority in their state of residence whose registration or participation on the Sites has not been authorized by their parent or legal guardian.
Special Rule for Site Users under 18.
Third Party "Linked-To" Web Sites.
Information Security and Storage.
The protection of your Personal Information is very important to us. To that end, we take reasonable steps to protect the Personal Information you share with us from unauthorized access or disclosure. However, you should know that no security measures are impenetrable and no company, including Sokanu, can fully eliminate security risks to its telecommunications and computer systems. In addition, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that information, during transmission through the Internet, will not be destroyed, hacked, hijacked, misdirected, stolen, modified or otherwise interfered with or misused. Accordingly, your transmission of information to or through the Sites is at your own risk.
We retain your Personal Information, including your Personally Identifying Information and Personal Financial Information for as long as we have a relationship with you. When deciding how long to keep this information after our relationship with you has ended, we take into account our legal obligations. We also retain records to investigate or defend against potential legal claims. If there is any information that we are unable to delete entirely from our systems for technical reasons, we will put in place appropriate measures to prevent any further processing or use of the data.
Rights to “Opt Out”.
If you are receiving emails, texts or similar online communications from Sokanu, it is because you consented or we understood from your participation on our Sites that you were interested in receiving ongoing information from us. If at any point you no longer wish to receive marketing communications, you may at any time “unsubscribe” from these communications by following the ‘opt out’ directions to be found at or near the end of the communication. We may still send transactional, non-marketing communications. If you have any questions about the opt-out process, you can contact us at email@example.com. Please note that if we have already shared your personal contact information with one of our business partners, unsubscribing from our communications list will not prevent these third parties from continuing to email or text you. You will have to send an opt-out request to those third parties directly. Opportunities to “opt out” from receiving emails and texts are usually found on these companies’ websites or at the end of their emails or texts.
Under applicable local law, California residents may have certain additional rights regarding the Personal Information we hold about them. These rights may include disclosure of the categories, specific pieces, and sources of Personal Information we collect, the purposes for which we disclose that information, and the categories of third parties to whom we disclose that information (see generally descriptions in sections 1-6 above). California residents may also request that we delete their personal information or not disclose their information to our partners, such as advertising partners, or other third parties as described in sections 7 and 8 above who use the information for their own purposes. Some of those arrangements may be deemed sales under the California Consumer Privacy Act, which has a broad definition of sale, and California residents can opt-out of those disclosures. We do not knowingly sell the personal information of minors under 16 years of age without affirmative authorization. We will not discriminate against you for exercising these rights. To exercise any of these rights, please submit your request at firstname.lastname@example.org or call us at 1 (805) 285-2268 or to opt-out of sales, click the “Do Not Sell My Personal Information” link on our website. For some of these rights you may have to provide us with additional information so that we can verify your identity.
We have shared all of the categories of personal information we collect (as described in section 1) for business purposes with service providers in the last 12 months. We also have shared identifiers, educational history, career history and demographic information with third parties in the preceding 12 months, including with school districts, individual schools, colleges and universities, vocational schools, organizations like the Job Corps, job search and recruiting services, career development services, and employment services.
Under applicable local law, EU residents may have certain rights regarding the Personal Information we hold about them. These may include the rights to access, correct, delete, restrict or object to our use of, or receive a portable copy in a usable electronic format of your Personal Information. You also may have a right to lodge a complaint with your local data protection or privacy regulator. We encourage you to contact us at the contact information set forth below to update or correct your information if it changes or if the Personal Information, we hold about you is inaccurate. Where you have provided your consent to any use of your Personal Information, and where applicable under local law, you can withdraw this consent at any time. Please note that we may require additional information from you in order to honor your requests.
International Data Transfer.
Your Personal Information and Personal Financial Information may be transferred to, stored, and processed in a country (such as the United States) that is not regarded as ensuring an adequate level of protection for personal data under your home country’s law, be it Canada, in the European Union, or elsewhere. We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your information is adequately protected. For more information on the appropriate safeguards in place, please contact us at the details below.
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