Effective Date: November 23, 2015
Introduction
Welcome! This privacy policy (“Privacy Policy”) governs the website www.lolatechsystems.com (including both mobile and online versions) (the “Site”) and the Lola mobile app (the “App”), including your use of interactive features, widgets, plug-ins, applications, content, downloads and/or other online services that we own and control and that post a link to this Privacy Policy (collectively, the Site and the App are referred to as the “Service”), which are made available by LOLA TechSystems, Inc., d/b/a Lola (“Lola”, “we” “our” or “us”).
Younger visitors to our Service should always check with their parents or guardians before entering information on any website or mobile application and we encourage families to discuss their household guidelines regarding the online sharing of personal information. If you are a child and you are reading this Privacy Policy by yourself, we recommend that you ask your parent or teacher to read it with you in order to help you understand what it means. Our Service is designed to comply with state and federal regulations enacted to protect the privacy of children, including, without limitation, to the extent applicable to the Service, the Children’s Online Privacy Protection Act (“COPPA”), the Federal Education Rights and Privacy Act (“FERPA”), and the California Education Code Section 49073.1.
The following Privacy Policy describes what information Lola collects about you, why we collect it, how we use it, and under what circumstances we share it with third parties. This Privacy Policy also describes the choices you can make about how we use your information. To the extent we provide you notice on our Service of different or additional privacy policies or practices (e.g., at the point of our collection), those additional terms shall govern such data collection and use.
This Privacy Policy does not apply to data we receive from third parties, unless we combine such data with Personal Information (defined below) that we have ourselves collected under this Privacy Policy. This Privacy Policy does not apply to our data collection activities offline or otherwise outside of our Service (unless otherwise stated below), and does not govern the data practices of third parties that may interact with our Service.
In addition, please review the Service’s Terms of Use, which governs your use of the Service. By using our Service, you consent to our Privacy Policy and Terms of Use and our collection, use and sharing of your information and data, and other activities, as described below.
Linkable Table of Contents
It is important that you read and understand the entire Privacy Policy before using the Service. To ease review, each section below contains a brief introductory summary and a link to the full explanation. Click on the headings and the “More” buttons to be taken to the full explanation. Any capitalized terms that appear in but are not otherwise defined in the introduction have the meanings given to them elsewhere in the Privacy Policy.
1. What Information Does the Service Collect?
We collect and receive certain information about you as you use and interact with our Service, explained further in this Section.
(a) Information You Provide to Us
We may collect certain Personal Information and Demographic Information (defined below) that you provide to us when you interact with the Service. For example, we may collect this information through various forms and in various places on the Service, including when you sign-up for an account to use the Service or when you otherwise interact with the Service. More
(b) Information Collected and Stored As You Access and Use the Service
Certain information may be collected from you automatically when you access and use the Service. For example, we and third parties may use Tracking Technologies (defined below) to collect Usage Information (defined below) based on your Device Identifier (defined below) for a variety of purposes, which may include activities over time and across third party locations. More
(c) Information Third Parties Provide About You
We may obtain information about you from third parties. More
(d) California Do Not Track Disclosures
We do not look for or respond to “do not track” signals, but you may have certain other options regarding tracking and/or targeting. More
(e) Information You Provide About a Third Party
You may provide us information about others, such as when you send a friend a message. If so, the information you provide (names, email addresses, etc.) may be used to facilitate the communication, but will not be used for other marketing purposes unless your friend consents. You may be identified to the friend in connection with such a message. More
2. How Do We Use The Information Collected?
We use your Personal Information, Demographic Information and Usage Information for a variety of purposes detailed in this Section. More
3. How and When Do We Share Information With Third Parties?
We may provide your information to third parties under various circumstances detailed in this Section. These may include:
(a) When You Request Information From or Provide Information to Third Parties
If you request information from third parties, request that we send information to third parties or interact with third-party web sites, content or tools, we may share your information with such parties and/or they may collect your information directly. More
(b) Third Parties Providing Services on our Behalf
Our vendors may collect your information on our behalf or we may share it with them so that they may provide services to us and you. Some may offer you choices regarding the collection and use of your information. More
(c) To Protect the Rights of Lola and Others
There are a variety of administrative and legal reasons for which we may share some or all of your information. More
(d) Affiliates and Business Transfer
We may share your information with our affiliates as well as in the event of a sale, merger or similar transaction. More
4. Does Third-Party Content, Links to Third-Party Sites and/or Third-Party Apps Appear on the Service?
We may allow you to access third-party content on the Service, or to link to third-party applications and locations from the Service, but we are not responsible for your interaction with third-party content, apps and locations. More
5. How Do I Change My Information and Communications Preferences?
You may change certain account information and communications preferences as more fully detailed in this Section. More
6. What About the Transfer of Information to the United States?
You consent to your data being transferred to the United States. More
7. What Should Parents Know About Children?
We do not intend to collect Personal Information from children. If you think we have, let us know. More
8. What About Security?
No data security is absolute, but we endeavor to take reasonable steps to secure data appropriately. More
9. What About Changes to the Privacy Policy?
We may change this Privacy Policy upon posting of a revised privacy policy. However, we will continue to treat your Personal Information under the terms of the privacy policy in effect when it was collected unless you otherwise consent. More
The Full Detailed Privacy Policy
(a) Information You Provide to Us
On the Service, we may ask you to provide us, or our service providers, with certain categories of information, such as: (1) personally identifiable information, which is information that identifies you personally, such as your first and last name, username and password, and email address (“Personal Information"); and (2) demographic information, such as information about your gender, experience, skills and education (“Demographic Information”). We may collect this information through various forms and in various places on the Service, including if you register for an account, through “contact us” forms, or when you otherwise interact with the Service. If we combine Demographic Information with the Personal Information we collect directly from you on the Service, we will treat the combined data as Personal Information under this Privacy Policy.
In addition to any Personal Information or other information that you choose to submit to us via our Service, we and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Service (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Service. To the extent we associate Usage Information with your Personal Information we collect directly from you on the Service, we will treat it as Personal Information.
This Usage Information may include:
your IP address, UDID or other unique identifier (“Device Identifier”). A Device Identifier is a number that is automatically assigned to your Device used to access the Service, and our computers identify your Device by its Device Identifier;
your Device functionality (including browser, operating system, hardware, mobile network information);
the areas within our Service that you visit and your activities there, including remembering you and your preferences;
your Device location;
your Device characteristics; and
certain other Device data, including the time of day, among other information.
We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). A few of the Tracking Technologies used on the Service, include, without limitation, the following (and subsequent technology and methods later developed):
Cookies. A cookie is a data file placed on a Device when it is used to visit the Service. A Flash cookie (or locally shared object) is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device. HTML5 cookies can be programmed through HTML5 local storage. Unlike Flash cookies, HTML5 cookies do not require a plug-in. Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard. Also, these tools may not be effective with regard to Flash cookies or HTML5 cookies. For information on disabling Flash cookies, go to Adobe’s website www.adobe.com. Please be aware that if you disable or remove cookies, Flash cookies, or HTML5 cookies on your Device, some parts of our Service may not function properly, and that when you revisit our Service your ability to limit cookies is subject to your browser settings and limitations.
Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1x1 GIFs” or “clear GIFs”) may be included in our Service’s pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or email can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Service, to monitor how users navigate the Service, to count how many emails that were sent were actually opened or to count how many particular links were actually viewed.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Service, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Service, and is deactivated or deleted thereafter.
Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
ETag, or entity tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies.
Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).
We may use Tracking Technologies for a variety of purposes, including:
Strictly Necessary. We may use cookies or other Tracking Technologies that we consider are strictly necessary to allow you to use and access our Service, including cookies required to prevent fraudulent activity, improve security or allow you to make use of Service functionality.
PerformanceRelated. We may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Service, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Service.
FunctionalityRelated. We may use cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing the Service, including identifying you when you use our Service or keeping track of your specific progress, including in terms of the presentation of content on our Service.
TargetingRelated. We may use Tracking Technologies to deliver content, relevant to your educational goals and interests on our Service and thirdparty services based on how you interact with our content. This includes using Tracking Technologies to understand the usefulness to you of the content that has been delivered to you.
Further, third parties may use Tracking Technologies in connection with our Service, which may include the collection of information about your online activities over time and across third-party websites or online services. We may not control those Tracking Technologies and we are not responsible for them. However, you consent to potentially encountering third-party Tracking Technologies in connection with use of our Service and accept that our statements under this Privacy Policy do not apply to the Tracking Technologies or practices of such third parties.
We may receive information about you from your school or school district. Additionally, we may, from time to time, supplement the information we collect directly from you on our Service with outside records from third parties for various purposes, including to enhance our ability to serve you, to tailor our content to you and to offer you opportunities that may be of interest to you. To the extent we combine information we receive from those sources with Personal Information we collect on the Service, it will be treated as Personal Information and we will apply this Privacy Policy to such combined information, unless we have disclosed otherwise. In no other circumstances do our statements under this Privacy Policy apply to information we receive about you from third parties, even if they have used our technology to collect it and share it with us.
Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms.
You may send someone else a communication from the Service, such as sending a message or invitation to a friend. If so, the information you provide (names, email addresses, etc.) is used to facilitate the communication and is not used by us for any other marketing purpose. Please be aware that when you use any send-to-a-friend functionality on our Service, your contact information, name or user name and message may be included in the communication sent to your addressee(s). Some of these tools may be third-party tools subject to third-party privacy policies.
(a) Use of Information by Us. We may use your Personal Information, Demographic Information or Usage Information that is subject to this Privacy Policy:
to process transactions or provide you with information, such as to send you electronic newsletters or to provide adult users of the Service, such as parents or teachers, with special offers or advertising, promotional and marketing materials, including for letting adult users know about new products, services or upcoming events;
to improve the Service, including our Service offerings;
to customize your experience on the Service or to serve you specific content that is relevant to you;
to provide customer support;
to contact you with regard to your use of the Service and, in our discretion, changes to the Service and/or Service’s policies;
to enable you to participate in a variety of the Service’s features such as to allow you to contact other users of the Service (e.g., student messaging a teacher);
to improve the overall experience at the Service;
for internal business purposes; and
for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.
However, the information collected by us on the Service will not be used to create user profiles for purposes of targeting students or their parents with third party behavioral ads.
We may share non-Personal Information, such as aggregated user statistics, with third parties. We may share your Device Identifiers with third parties along with data related to you and your activities. In addition, we may share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information and as described below or otherwise in this Privacy Policy. We will not share your Personal Information with third parties for a third parties’ direct marketing purposes unless we specifically obtain your consent to do so. We may disclose your information as follows:
Adult users may be presented with an option on our Service to receive certain information and/or offers directly from third parties or to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties. In addition, third parties may store, collect or otherwise have access to your information when you interact with their Tracking Technologies, content, tools, or apps on our Service or link to them from our Service. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review such third-party privacy policies and practices of such third parties prior to requesting information from or otherwise interacting with them.
We may use third-party vendors to perform certain services on behalf of us or the Service, such as: (i) to assist us in Service operations; (ii) to manage a database of customer information; (iii) hosting the Service; (iv) designing and/or operating the Service’s features; (v) tracking the Service’s activities and analytics; (vi) enabling us to send you special offers or perform other administrative services; and (vii) other services designed to assist us in maximizing our business potential. We may provide these vendors with access to user information, including Device Identifiers and Personal Information, to carry out the services they are performing for you or for us. Third-party analytics and other service providers may set and access their own Tracking Technologies on your Device and they may otherwise collect or have access to information about you, potentially including Personal Information, about you. We are not responsible for those third party technologies or activities arising out of them. However, some may offer you certain choices regarding their practices, and information we have been informed of regarding such choices is available here. We are not responsible for the effectiveness of or compliance with any third parties’ opt-out options.
We may access, use, preserve, transfer and disclose your information (including Device Identifiers and Personal Information) to third parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process if in our good faith opinion such is required or permitted by law; (ii) to protect and/or defend the Service’s Terms of Use or other policies applicable to the Service, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Service or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues. Further, we may use IP address or other Device Identifiers to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion, subject to applicable law. Such disclosures may be carried out without notice to you.
We may share your information, including your Device Identifiers and Personal Information, Demographic Information and Usage Information with our parent, subsidiaries and affiliates. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Service or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.
The Service may contain content, links or apps that are supplied by a third party, and those third parties may collect Usage Information and your Device Identifier when pages from the Service are served to you for their own commercial purposes. In addition, when you are on the Service you may be directed to other sites and apps that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any of these third parties or their sites or apps and they may be tracking you across multiple online services and may be sharing the results of that tracking with us and/or others. These third parties may have their own terms of service, privacy policies or other policies and ask you to agree to the same. For example, if you “click” on a link, the “click” may take you off the Service onto a different location. These other online services may associate their Tracking Technologies with you, independently collect information about you, including Personal Information, and may or may not have their own published privacy policies. We are not responsible for these third-party privacy policies or the practices of Third-Party Owners. Be sure to review any available policies before submitting any personally identifiable information to a third-party application or otherwise interacting with it and exercise caution in connection with these applications. We also encourage you to note when you leave our Service and to review the third-party privacy policies of all third-party locations and exercise caution in connection with them.
You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration. The Service may allow you to review, correct or update Personal Information you have provided through the Service by updating your Service account, and you may provide registration updates and changes by contacting us by email at: support@lolatechsystems.com. If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons. When you edit your Personal Information or change your preferences on the Service, information that you remove may persist internally for Lola’s administrative purposes. You may cancel or modify our email marketing communications you receive from us by following the instructions contained within our promotional emails. This will not affect subsequent subscriptions and if your opt-out is limited to certain types of emails the opt-out will be so limited. Please note that we reserve the right to send you certain communications relating to your account or use of our Service, such as administrative and Service announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications.
If you have any questions about the Privacy Policy or practices described in it or if you would like to have your information permanently deleted from our databases, you should contact us in the following ways: Postal Mail: Lola Tech Systems, Inc. 2345 Outpost Drive, Los Angeles, CA 90068 (Attn: Privacy Officer); Email: support@lolatechsystems.com.
Our Service is operated in the United States and intended for users located in the United States. If you are located outside of the United States, please be aware that information we collect, including Personal Information, will be transferred to, and processed, stored and used in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Service or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in the United States as set forth in this Privacy Policy.
We understand the importance of protecting children’s privacy in the interactive world. We recognize the need to provide further privacy protections with respect to personal information we may collect from children under the age of thirteen (13) (“Child” or “Children”) and do not knowingly collect personal information from Children on the Service that requires either parental/guardian or school district notice and consent under COPPA without first obtaining such consent.
When we intend to collect personal information from Children, we take additional steps to protect Children’s privacy, including:
Notifying either parents or the schools/districts about our information practices with regard to Children, including the types of personal information we may collect from Children, the uses to which we may put that information, and whether and with whom we may share that information.
In accordance with applicable law, obtaining consent from parents or schools/districts for the collection of personal information from their Children, or for sending information about our products and services directly to their Children.
Limiting our collection of personal information from Children to no more than is reasonably necessary to participate in an online activity.
Giving parents and/or schools and districts access or the ability to request access to personal information we have collected from their Children and the ability to request that the personal information be changed or deleted.
In the event that we become aware that we have collected personal information from any Child without first having obtained consent from a parent or school/district, we will dispose of that information in accordance with COPPA and other applicable laws and regulations. If you are a parent or guardian or a school or school district and you believe that a Child under the age of thirteen (13) has provided us with personal information without obtaining COPPA-required consent, please contact us at legal@lolatechsystems.com.
We endeavor to incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our Service and provide us with your information at your own risk.
We reserve the right to change this Privacy Policy at any time. Any changes will be effective immediately upon the posting of the revised Privacy Policy and your use of our Service indicates your consent to the privacy policy posted at the time of use. However, we will not use your previously collected Personal Information in a manner materially different than represented at the time it was collected without your consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.
//End Privacy Policy//
*The link in Section 3(b) should go to the following:
The following third parties that collect information from you on the Service have given us notice that you may obtain information on their policies and practices, and in some instances opt-out of certain of their activities, as follows:
Party
Service
For More Information
Use of Tracking Technologies
Privacy Choices
Google Analytics http://www.google.com/analytics/learn/privacy.html
https://tools.google.com/dlpage/gaoptout/
PLEASE NOTE: We are not responsible for third-party policies or practices. We try to keep this information current, and will add to and subtract from the chart above as appropriate, but it is provided as a courtesy and may not be current or accurate. Please contact the relevant third parties regarding their privacy and data security policies and practices.
Copyright © 2015 LOLA TechSystems, Inc. All rights reserved.