INFORMATION |
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| Data Controller: | Learning Bits, Inc. (hereinafter, «Science Bits,» «the company,» «we,» «our,» or «us») C/OGLSC & CO 6303 BLUE LAGOON DRIVE, SUITE 200 MIAMI, FL 33126 TIN: 47-4586856 |
| Contact: | [email protected] |
| This privacy policy explains the types of personally identifiable data we collect, why we collect it, and how we use and share it in connection with this website and for other purposes identified in this privacy policy. | |
| By accessing this website, you acknowledge and understand that you acquire the capacity of a user and where we refer to «user» herein we are also referring to you. | |
| Purposes of the data processing | Your data may be processed, as appropriate, for the following purposes:
If there is any other purpose not included in this list that is applicable in a specific case, you will be informed immediately and your consent will be requested, when appropriate. |
| Legal Grounds | The legal grounds that allow the company to process your data are, as appropriate, the following:
If other legal grounds are applicable to a specific case, you will be informed immediately. |
| Categories of the data recipients | The only recipients of your data will be the company, Science Bits, and the other companies of the group and the professionals who provide service to us by virtue of a contract as data processors. In each case, the personnel of these companies will have access to the data where required. Public or legal authorities may also eventually have access to your data if they require it to carry out their duties. |
| Categories of personal data |
Based on the specific case, we can collect the following types of user data:
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| The source of the data | The user data that the company holds has been obtained either:
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| International data transfer | All US customer data stored in the US is managed according to the GDPR and EU data protection laws as the European Commission has determined that the US does not require the same level of data protection as the European Union.
Where we collect, receive or process personal data outside of the European Union in connection with the purposes described in this privacy policy, and specifically addressing the storage or transfer of data to the US, users acknowledge and understand that the party in the US receiving the personal data may agree to standard data contractual clauses («SCCs») under which the receiving party guarantees to safeguard the personal data it receives. Where personal data is transferred to the US based on SCCs, the company will take into account the circumstances surrounding the transfer and any supplementary measures that demonstrate that the US law does not impinge on the promise of adequate data protection set forth in the SCCs. If legally permissible, we may rely on your express consent to transfer your personal data rather than the SCCs. In some cases, personal data may also be requested, stored or transferred to the US in other ways permitted under the laws of the European Union and Privacy Shield 2.0. In the event your personal data is transferred, if you would like to request the specific safeguards applied to the export of your personal data, if applicable, you may send your request to us at [email protected]. |
| Data storage period | Your data will be stored the necessary amount of time to comply with the purpose for which said data was obtained unless you withdraw your consent beforehand, never exceeding the legally established limits. If required by law or by a legal order, we may process and store your personal data for a longer period consistent with the law or legal order or our contractual rights. For example, we may need to keep your personal data longer if necessary to fulfill obligations to preserve records under tax law or for accounting purposes, or if we are obligated to hold personal data because of a legal prohibition against removing or deleting it.
The data may later be stored with the mere purpose of providing a response to future requests from a competent authority. |
| Rights |
The privacy of those who visit this website is important to us. We support the goals and guidelines set forth by oversight laws and bodies such as:
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| How does Science Bits comply with AB 1584? | In order to ensure that Science Bits is compliant with AB 1584, where a contract is present with both local education authorities and third parties, each contract will contain certain provisions, including the following:
We design and operate our technology and services with our users’ protection and privacy in mind. This privacy policy outlines the types of information we gather when users access this website, technology and services, as well as some of the steps we take to safeguard it against unauthorized use. Users are also informed that Science Bits will not use their data to take automated individual decisions or to create profiles. Likewise, users are reminded that they can transfer the data requested in the contact form on the website of their own free will. However, it must be taken into account that the sections that appear with an asterisk (*) are mandatory if the user wants to contact us given that, based on the nature and type of service that Science Bits provides, this information is required for the company to manage the query, application, service or request you have sent. Concerning the company contracts and licenses, users must take into account that they are free to provide the data requested, but by not doing so, our contractual relationship cannot be formalized nor can the license be used as the data must be provided for this purpose. REMINDER: Minors, that is persons under 18 years old, cannot contract the services that our website offers. We would like to inform you that, in accordance with current legislation, minors, except those who have obtained legal emancipation, cannot enter into contracts. In the event that a contract is entered into with a minor, said contract would be rendered null and void except with the authorization of the parents or legal guardians. Science Bits will not sell or market directly to minors and always seeks parental or legal guardian’s authorization whenever we identify that a minor attempts to purchase a Science Bits product or service or provide personally-identifiable information to us. Minors may not use this website without parental consent. If we learn that any personal information about any minor has been collected without parental consent, then we will take reasonable steps to delete any such information. A note to parents of kids under 18: In compliance with COPPA, Science Bits requires that schools and districts provide verifiable consent from parents before we collect and use any information from students. A note to kids under 18: Please get permission from your parents/legal guardians before using the Science Bits website or sending any e-mail to us or to anyone on the Internet. If you wish to subscribe to the Science Bits website, your parents/legal guardians need to complete the subscription form for you. A note to educators: Please get permission from the minors’ parents/legal guardians before allowing minors to use the Science Bits website or to send any e-mail to us or to anyone on the Internet. |
| COPPA Compliance | Science Bits does not collect any personal information from a Child User unless a School Customer or educator provides, on behalf of a parent or guardian, such information or authorizes the collection of such information to provide the Science Bits service. Science Bits complies with all applicable provisions of COPPA. To the extent COPPA applies to the information we collect, such information is processed for educational purposes only, under the direction of the partnering School District or State Agency and on the basis of educational institutional consent. |
| FERPA Compliance | Any collection and use of Student Data is governed by our Agreements with Districts, including this Privacy Policy, and applicable laws including the federal Family Educational Rights and Privacy Act of 1974 (“FERPA”), the Children’s Online Privacy Protection Act (“COPPA”), as well as other applicable federal, state, and local privacy laws and regulations (“Applicable Laws”). For the avoidance of doubt, Science Bits receives Student Data as a “school official” under Section 99.31 of FERPA for the purpose of providing the Science Bits service, and any and all such Student Data is owned and controlled by the District or Customer. |
| Data controller | The company is the data controller or data owner responsible for determining the purposes for which personal data discussed in this privacy policy is collected, used, and shared.
If you have any questions about this privacy policy or our data collection practices, please contact us at the address, telephone number, or email address noted above, and specify your country of residence and the nature of your question. This privacy policy applies to the information that Science Bits collects from users through its website, electronic communications, contact forms, instant messaging services and any other service that we enable to improve our users’ experience. This is also applicable to other communications in which we specifically refer to this privacy policy. The privacy policy will be updated from time to time in order to clarify or reflect new practices in the management of our users’ privacy or the legal modifications that must be applied. If we decide to change this privacy policy, we will post the revised privacy policy on our website. All the modifications will be sent to users by email and by notifications on the website. In certain cases, we may also seek your consent or give you the right to opt out of our use of your personal data in accordance with the revised privacy policy, if required. However, because we may make changes at any time, we suggest that you periodically consult this privacy policy. Please note that our data protection practices will be based on the privacy policy in effect at the time your personal data is processed. |
| When we collect your personal data | If a user interacts through our website or if a user registers through our social network, we will process their demographic data, their operating system, their cell phone data (if the user accesses the website through this device) and, in general, information about sessions, number of visitors, number of pages visited, number of pages that each visitor visits in each session, the average duration of the session, the bounce rate and the percentage of new sessions.
a) Means through which your data and information is collected We will process user data whenever a user:
The personal data that the user provides us will be incorporated in our files. b) The different times in which we collect user data are:
For more information on this matter, consult our COOKIES POLICY. |
| Data collection purposes | The personal data that users provide us by accessing their account or by using our services will be used for the management, administration, provision, expansion and improvement of our services, specifically those to which the user has registered or used, as well as to keep users up-to-date about improvements and news of the services that we offer or any other related purpose. This is also applicable for the other purposes detailed previously.
When a user uses our contact form, after accepting the privacy policy and terms and conditions, they will provide us their consent so that their personal data and the rest of the information that the user has provided us are used to manage their contact, query or request. In certain cases part of their information will be published and indexed by web browsers. If a user does not want this information to be public, they must re-edit their data through the user menu. |
| Third-party personal data | If a user has included personal data from other people, the other person or persons must be informed of our policy and conditions, as well as the use that we make of the data, and must have given their prior consent. |
| Exercising Rights | Users have the right to request from us the access to any personal data that we have about the user and ask that we update, correct or delete the data, that we no longer use it, and to object to data processing, as well as to limit the portability of their data, limit their processing and withdraw their consent if the user so requests.
If a user wants to exercise their rights, they should write an email to [email protected] or to enabled links in our emails or publications. Remember that the user must provide the most detailed information possible: name(s) and surname(s), ID document, and email address. |
| Account closure and withdrawal procedure | Any user may withdraw as a user from the website by going to their user area. By withdrawing, the information and data that may be in the account will be lost, as well as the right to enjoy any benefits that the fact of being a user may provide them.
In the case of withdrawal, we can maintain all the users’ personal data during the period of time necessary to be able to ensure the exercise of our processes and legal obligations and to resolve possible disputes. All the user’s personal data will be processed and saved to the strictly necessary measure to comply with the law or with the purposes that we have described. When the user’s data are no longer pertinent for the purposes for which they have been collected, the data will be deleted. |
| With whom we share user data |
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| Veracity of the data and responsible use |
The fact of having an account or being a user of Science Bits implies that the user must ensure the veracity of the information provided, and that it is up-to-date, and that it belongs to them. For this reason, users are responsible for ensuring that their data are correct and of suitable quality. Therefore, we reserve the right to verify this information at any time, requesting an official certification document or equivalent procedure and to disable or delete their account if we find any irregularity. Science Bits ensures the security and confidentiality of user data and for this reason we adopt the technical security measures to prevent their loss, undue use or access to unauthorized individuals. However, we shall not be held liable for the information that you decide to share with other users. We are committed to acting quickly and responsibly in the case that the security of user data is affected and informing users if deemed relevant. |
| Use of plug-ins or social complements | When a user uses our website, the user accesses our social networks such as Facebook, Twitter, Instagram, YouTube and LinkedIn, through an incorporated social plug-in.
If a user chooses to share information through a social plug-in, we do not have any involvement with the information that social networks collect through the use of plug-ins, but it must be taken into account that your browser will transfer the following data to said social network. (a) Date and time of visit. |
| Special or third-party privacy policies |
a) Special privacy policies b) Third-party privacy policies |
| Security measures | Science Bits has implemented the necessary security measures to guarantee that the data are used and processed effectively, that it protects the intimacy, privacy and confidentiality of these data, complying with the requisites set forth in the current legislation, employing the necessary means to prevent the processing, alteration or loss of user data or the unauthorized access thereof, according to the state of the technology at any given time, as well as the scope of Science Bits’ control. |
| DO-NOT-TRACK | You may have implemented a «do-not-track» signal through your browser. As there currently is no fixed standard for do-not-track signals, we currently do not respond to do-not-track signals from your web browser. |
| BUSINESS TRANSITIONS | In the event we go through a business transition, including without limitation any merger, acquisition, partnership, business reorganization, debt finance, or sale of assets, or in the event of an insolvency, bankruptcy, or receivership (each a «Business Transition»), we may use and disclose information collected in accordance with this privacy policy as part of any that Business Transition, and your personal data may be part of any assets transferred. |
SUPPLEMENT TO PRIVACY POLICY: RIGHTS OF CALIFORNIA RESIDENTS
This Supplement to our privacy policy (the «Supplement») is part of our privacy policy and is directed to you if you are a California resident and therefore have certain rights under the California Consumer Protection Act of 2018 («CCPA»). The Supplement applies to personal information we collect when we operate as a «business» as defined under the CCPA. This Supplement describes what those rights are and how you may exercise them when we act as a business. If there is any term in this Supplement that conflicts with a term in our privacy policy, the term in this Supplement shall control.
When we operate as a «service provider» (as defined under the CCPA) for our customers and they provide us with your personal information for business purposes under a service contract, the CCPA applies primarily to those customers, not to us. In such cases, we will direct any requests you send us to exercise your rights under the CCPA to the applicable customer.
1. INFORMATION WE COLLECT AS A BUSINESS
We collect the following categories of personal information as defined under the CCPA:
Type of information |
Examples |
Collected by Us |
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| Identifiers | Name, postal address, e-mail address, IP address, phone number and similar identifiers. See sections entitled, «CATEGORIES OF PERSONAL DATA,» «WHEN WE COLLECT YOUR PERSONAL DATA,» and our «COOKIES POLICY» in our privacy policy for details. | Yes |
| Information specified in California Consumer Records statute | Name, signature, postal address, telephone number, employment. See section entitled, «CATEGORIES OF PERSONAL DATA» in our privacy policy for details | Yes |
| Protected classifications under California or federal law | Age, race, national origin, citizenship, religion or creed, marital status, gender, sexual orientation, health status | Yes |
| Commercial information | Records of personal property, products, services purchased or purchasing histories | Yes |
| Biometric information | Genetic, physical, behavioral or biological characteristics, such as fingerprints, iris scans, voiceprints, health/exercise or sleep data | No |
| Internet and similar network activity | Browsing history, website analytics, app interactions. See section entitled, «WHEN WE COLLECT YOUR PERSONAL DATA» and our «COOKIES POLICY» in our privacy policy for details | Yes |
| Geolocation data | Physical locations and/or movements | Yes |
| Sensory data | Audio, visual, or similar data related to physical characteristics | No |
| Professional or employment-related information | Current employment or job history | Yes |
| Non-public educational information | Educational records protected under federal law | Yes |
| Inferences drawn from other personal information | Profiling of preferences, personal characteristics, behavior, attitudes or aptitudes | No |
Personal information does not include: (i) information publicly available from government records, (ii) deidentified or aggregated information, or (iii) information addressed by certain state and federal data privacy laws.
2. CATEGORIES OF SOURCES OF INFORMATION WE COLLECT
We obtain the categories of information described in this Supplement from the same categories of sources as described in the section entitled, «CATEGORIES OF PERSONAL DATA» of our privacy policy.
3. OUR USE OF PERSONAL INFORMATION
We use the personal information we collect, as described in this Supplement, for the same «PURPOSES OF THE DATA PROCESSING,» «DATA COLLECTION PURPOSES,» «LEGAL GROUNDS,» and as also identified above in our privacy policy in the section entitled, «WHEN WE COLLECT YOUR PERSONAL DATA» in addition to for use in connection with the sharing of such information with public agencies and service providers in accordance with the section within our privacy policy entitled, «WITH WHOM WE SHARE USER DATA,» «BUSINESS TRANSITIONS,» and as explained in our COOKIES POLICY.
4. OUR DISCLOSURE OF PERSONAL INFORMATION
We may disclose the personal information we collect, as described in this Supplement, for any of the same purposes and to the same categories of persons and entities as identified in the sections of our privacy policy entitled, «PURPOSES OF THE DATA PROCESSING,» «DATA COLLECTION PURPOSES,» «LEGAL GROUNDS,» «CATEGORIES OF THE DATA RECIPIENTS,» «WHEN WE COLLECT YOUR PERSONAL DATA» DATA COLLECTION PURPOSES in addition to for use in connection with the sharing of such information with public agencies and service providers in accordance with the section within our privacy policy entitled, «WITH WHOM WE SHARE USER DATA,» «BUSINESS TRANSITIONS,» and as explained in our COOKIES POLICY.
5. YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION
The CCPA gives certain rights to California residents regarding their personal information. We summarize below what those rights are and how you may exercise them. You do not need to have an account with us to exercise these rights.
The CCPA also gives California residents the right to opt out of (or for minors under 16, the ability to opt in to) sales of their personal information. However, we do not and will not sell your personal information. If, in the future, we decide to sell personal information, we will provide you with notice and the right to opt-out of (or for minors, opt-in to) such sales.
- Right to Know About the Collection, Use, Disclosure, and Sale of Personal Information
- Upon providing us with a verified consumer request, you may ask us to disclose certain types of your personal information we have collected and used over the 12-month period prior to the date of your request. You may make this request only twice within any 12-month period. You may request:
- The categories of personal information we collected about you;
- The categories of sources of the personal information we collected about you;
- The business or commercial purpose for collecting that personal information;
- The categories of third parties with whom we shared that information;
- The specific pieces of personal information we collected about you (except to the extent prohibited under the CCPA including, for example, disclosure of Social Security numbers or other government, health insurance or medical identification numbers, account passwords); or
- If we disclosed your personal information for a business purpose, a list identifying the personal information we disclosed to each category of recipient.
- Right to Request Deletion of Personal Information
- You have the right to submit a verified consumer request at any time that we delete any of your personal information collected and retained by us, unless an exception under the CCPA applies.
- If no exception applies, and if we have been able to verify your consumer request, we will delete, aggregate, or de-identify your personal information from our records in accordance with the CCPA. We will also direct third parties to whom we have disclosed your personal information to delete it, although we cannot guarantee that such third parties will comply with our direction. If no exception applies, and if we have been able to verify your consumer request, we will delete, aggregate, or de-identify your personal information from our records in accordance with the CCPA. We will also direct third parties to whom we have disclosed your personal information to delete it, although we cannot guarantee that such third parties will comply with our direction.Please note that we may deny your deletion request based on certain provisions of the CCPA, including where it is necessary for us or our service providers to carry out certain business functions, comply with laws or to engage in other internal and lawful uses of the information within the context in which you provided it to us.
6. MAKING A VERIFIED CONSUMER REQUEST TO US
To make a request to exercise your rights under the CCPA as described above, please submit a verifiable request to us by sending an email to us at [email protected] and include the phrase «CCPA Request» within the header of your email.
A verifiable consumer request must be made by you or a person registered with the California Secretary of State whom you have authorized to make the request on your behalf. (A representative must be authorized by you in writing or have a valid power of attorney under California probate law.) You may also make a verifiable request to us on behalf of your minor child.
To be considered a proper verified request, your request must:
- (1) provide us with sufficient information allowing us to reasonably verify that you are the same person about whom we collected the personal information or the authorized representative, and
- (2) describe your request in reasonable detail so we can correctly understand, evaluate, and respond to the request.
We may ask you for additional information, if needed, in order to verify your request, but if we do, we will use such additional information only to verify your identity (or the authority of the representative) and for security and fraud-prevention purposes.
We may also ask you to separately confirm any request to delete personal information via your website account or through another means.
7. RESPONDING TO YOUR VERIFIABLE CONSUMER REQUEST
We will use reasonable efforts to respond to your verifiable consumer request within 45 days of receiving it. In some cases, we may require more time (up to 90 days). If that is the case, we will communicate to you in writing (by postal mail or electronically, at your option) the reason and the length of anticipated delay. We will not be able to fulfill your request if we cannot verify your identity (or the authority of your representative) and confirm that the personal information subject to the request relates to you.
Disclosures we provide in response to a verified consumer request will cover only the 12-month period before we received the request. If your request involves the porting of your personal information, we will use a format that is reasonably designed to allow you to transmit the information to another entity. If we deny part or all of a verified consumer request, we will provide a reasonable explanation for the denial.
We do not charge fees for responding to verifiable consumer requests unless they are excessive, repetitive or manifestly unfounded. If we determine that a fee is appropriate, we will provide you with an explanation and a cost estimate before we complete your request.
We will keep records of consumer requests and our responses as required under the CCPA.
8. NON-DISCRIMINATION
We will not discriminate against you for exercising any of your rights under the CCPA. This means that, except where permitted under the CCPA, if you make a request for disclosure or to delete your personal information, we will not (i) deny you goods or services, (ii) charge you different prices for goods or services (e.g., through penalties or withholding of otherwise available discounts), (iii) giving you a different level of goods or services, or (iv) suggesting to you that we will take any of the actions in (i) through (iii).
9. HOW TO CONTACT US TO EXERCISE YOUR CALIFORNIA RIGHTS
If you have questions about our privacy policy or this Supplement, please feel free to contact us at: [email protected].
This document was last updated on November 1, 2023
| DETAILED INFORMATION ON DATA PROTECTION | |
|---|---|
| Introduction | Learning Bits, S.L. (hereinafter, the «Data Controller» or «LB») is especially aware of the protection of personal data. Because of this, it has adapted its entire structure to compliance with Regulation (EU) 2016/679 of the European Parliament and the Council on Personal Data Protection (hereinafter, «RGPD») and Organic Law 3/2018, of 5 December, on Personal Data Protection and guarantee of digital rights (hereinafter, «LOPDGDD»). |
| GENERAL INFORMATION | |
| Data Controller Details | Name: Learning Bits, S.L.
CIF: B-65569790. Address: Barcelona, calle Sant Joan de la Salle 37, 08022. To contact our Data Protection Officer, write an email to [email protected] |
| International Transfers | LB needs, in order to provide the requested services, to make international transfers of your data, to countries located outside the European Economic Area always provided an adequacy decision has been adopted, or failing that, they have deployed the appropriate guarantees, such as the standard contractual clauses. |
| Retention Period | The personal data will be stored for as long as the purpose for which they were collected continues in force and, once this has ended, the data will be stored duly blocked for the sole purpose of attending to the possible legal liabilities that may arise from the relationship that was established. |
| How to Exercise Your Rights | Data subjects may exercise their rights of access, rectification, erasure, portability, and limitation or right to object by writing to the mailing address of the Data Controller, or email at [email protected], attaching an identification document. They may contact the Spanish Data Protection Agency (www.aepd.es) to file a claim when they do not consider their request has been properly addressed. |
| More Information | If you would like more information about any of the items in this privacy policy, you can write to us at [email protected]. |
| 1. Web Management | |
| Purpose |
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| Legal Basis | The legal basis for the processing of this data is:
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| Recipients |
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| 2. Managing CVs | |
| Purpose | To manage the job applications received and the selection processes, as well as to carry out communications related to them and, where appropriate, for their inclusion in the candidate pool in order to take the application into account in future processes. Furthermore, the processing will include the management of the attendance of participants to the Learning Bits, S.L. premises in case of an in-person interview. |
| Legal Basis | Consent of the data subject provided by means of a clear affirmative action. Failure to provide the necessary data or information will result in us not being able to consider your CV or job application. The data subject has the right to revoke their consent without this affecting the processing based on consent prior to its withdrawal by sending an email to: [email protected] indicating their objection to the processing of their data for the purpose for which they gave their consent. |
| Recipients | No data assignments are planned.
The providers of the following services will have access to your data: hosting; user management platforms; mailing; legal; labour and tax consulting; auditing; and staff selection. |
| 3. Customer Management and Promotion | |
| Purpose |
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| Legal Basis | Execution of a service agreement in which the data subject is a party with respect to purposes 1, 2 and 3.
Law 34/2002, of 11 July, on Information Society and E-commerce Services, provided that the electronic commercial actions are for products or services that are similar to those that were initially contracted with any data subject with whom a contractual relationship is maintained for the provision of services, with respect to purpose 4. The consent of the data subject provided by means of a clear affirmative action with respect to purpose 5. Not providing the necessary data or information will result in us not being able to take your request into account. You have the right to revoke the consent without affecting the processing based on the consent prior to your withdrawal by sending an email to [email protected] indicating your objection to the processing of your data for the purpose for which you gave your consent. The legitimate interest of LB with respect to purpose 6. |
| Recipients | The following data communications are planned for legal and contractual reasons: to the Revenue Service and to the Social Security; to notaries and registrars; to the companies of the group, namely: Learning Bits INC, Learning Bits Sociedad de Responsabilidad Limitada de Capital Variable; and to financial entities. Conversely, providers of the following services will have access to your data: hosting; user management platforms; network security; educational; mailing; legal; consulting; marketing; auditing; and in the event of non-compliance with a monetary, financial or credit obligation, the data may be provided to a debt collection company. |
