In the context of this Policy, Compete to Create acts as a data controller for the information we process, with the exception of information processed solely pursuant to the instruction of your institution, business organization, or another controller, in which case Compete to Create acts as a data processor. If you are an institution or business organization with users under the age of 18 read about Compete to Create’s commitment to the Privacy of Minors, including students.
2. Information We Collect About You
Compete to Create collects information from you when you purchase, redeem, download, access or use any content or the Products; register a Product with Compete to Create; create an account; take notes or participate in assessments in a Product; use collaboration features; submit requests; and access Products, including when you visit any of our websites; as described further below.
a. Information You Provide Directly to Us
Depending on the Products you use, the types of Information we collect includes your name, address, email address, phone number, other contact information, academic institution, payment information collected and used by our third party payment processors such as credit or debit card numbers, information regarding your use of the Products, and user-generated content such as notes, highlights, and responses to assessments; and any other type of Information or Personal Data you submit to us at your discretion.
You can elect not to provide such Information, but, in general, most of the Information we request from you is required in order for us to provide the Products and the lack of such Information will prevent us from doing so. We will collect, use, transfer and disclose this Information as described in this Policy.
b. Information We Receive from Third-Parties
We receive Information from third parties, such as educational institutions, the identity of your business organization or representatives (if you are a corporate customer), third-party authentication services (if you interact with us through third-party sites or services) and the parties with whom we exchange Information as described here.
c. Information That Is Automatically Collected
Compete to Create automatically collects certain Information as you use the Products, make Product purchases and interact with us. We and our service providers (which are third-party companies that work on our behalf), may use a variety of technologies, including cookies and similar tools, to assist in collecting:
· technical data, such as your domain name, the browser type and language, and operating system you are using, your Internet Protocol (IP) address, country, and city, your device types, mobile device identifier, the date and time of your request, if any, and the device you are using, referring and exit pages and URLs, platform type, landing pages, error logs, and other similar information; and
· usage data, such as the date and time of your requests, the number of clicks, information you download, which Products you use and how you use them; pages viewed and the order of those pages, the amount of time spent on particular pages, the terms you use in searches on our sites; information from interactive Products, including scores from assessments, engagement during study sessions and overall performance, and records of any contact we have with you by telephone, email or online.
· We may use third-party web analytics services (such as those of Google Analytics) on our Services to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on.
· If you receive an email from us, we may use certain analytics tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications.
We keep your Personal Data for no longer than necessary for the purposes for which it is collected and processed. The length of time for which we retain Personal Data depends on the purposes for which we collect and use it, the instructions of a controller when we act as a processor, and/or our requirements to comply with applicable laws.
3. Using Your Information
Depending on the Product you use, we use your Information to:
· meet our contractual commitments to you,
· administer your account and respond to your requests,
· provide the Products you request,
· maintain and improve the Products and to develop new Products,
· provide you with information related to the Products, including changes to the Products, or other information we think you may find useful about our products and services or those of carefully selected third parties, provided you have indicated that you do not object to being contacted for these purposes,
· customize content supplied to you based on your use of the Products (e.g., study recommendations, supplemental content),
· to track, evaluate, and analyze individual and aggregate use of the Products and to share, publish, or otherwise publicize information, but not Personal Data, describing such use,
· provide recommendations or advertising for products and services that may be of interest to you,
· prevent, investigate and deal with fraud, violation of intellectual property rights and other laws and unauthorized use of Products or your account,
· as otherwise reasonable and appropriate to the legitimate business needs of Compete to Create related to the Products,
4. Sharing Your Information
If we share Information, including Personal Data, with third parties we require the recipient to maintain appropriate levels of confidentiality, integrity, availability and data protection for such Personal Data, and we will never sell Information to any third party. We share information as follows:
· With enterprise clients, Compete to Create shares anonymized information related to your use, results from your interaction with, results from assessments taken, and overall engagement with relevant Products, including interactive elements.
· With trusted third parties performing certain tasks on our behalf. For example, this may include but is not limited to service providers providing customer support, operation and administration of the Products, processing information that you provide to us, and other tasks related to the Products. We allow these third parties to access only the information needed to perform those services.
· With other visitors to the Product or users of the Product. To the extent that you submit content to publicly accessible portions of the Product, visitors and users may be able to view your content and Personal Data that identifies you as the author.
· As otherwise described to you at the point of collection, pursuant to your consent, or as otherwise permitted by law.
5. Your Rights and Choices
· Data Subject Rights: You have certain rights with respect to your Information as further described in this section. If you would like further information regarding your legal rights under applicable law or would like to exercise any of them, please contact us as described in the Contacting Us section of this Policy.
· You can tell us not to contact you with promotional information regarding our Products and services and those of third parties either at the point information is requested on our website (by checking or un-checking (as directed) the relevant box), or by following the unsubscribe instructions on promotional communications sent to you. You can also exercise this right at any time by contacting us using the Contacting Us details at the end of this Policy.
· You may request that we:
· provide access to and/or a copy of certain information we hold about you;
· prevent the processing of your information for direct marketing purposes (including any direct marketing processing based on profiling);
· update information at is out of date or incorrect;
· restrict the way that we process and disclose certain of your information;
· transfer your information to a third-party provider of services; and
· revoke your consent for the processing of your information.
· delete certain information we are holding about you (a request that you be “forgotten”).
Please note, however, that certain information may be exempt from such requests in some circumstances, which may include circumstances under which we need to continue processing your information for our legitimate interests or to comply with a legal obligation. An exercise of the right to be forgotten will result in your inability to use the Product(s) and will break any linkage between your prior account and your historical engagement data.
Request Content & Responses:
· We may request that you provide us with information necessary to confirm your identity before responding to your request. In the case of access and correction requests, please provide as much detail as you can about the particular personal data you seek, in order to help us locate it.
· We will consider all requests and provide our response promptly, and within any time period rquired by applicable law.
· Where we decide not to make a requested correction to your personal data and you disagree, you may ask us to make a note of your requested correction with the data.
· In situations in which we process your personal data only on behalf of a customer such as an enterprise institution, we may refer your request to the relevant party and cooperate with its handling of the request.
· California Online Privacy Protection Act Notice Concerning Do Not Track Signals. We do not recognize or respond to browser-initiated Do Not Track (“DNT”) DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. Visit All about DNT to learn more about Do Not Track.
Compete to Create takes information security seriously and has taken various measures to keep your Information secure from unauthorized access or disclosure, whether that Information is stored physically or electronically. Compete to Create has established administrative, technical, physical, electronic and managerial procedures to help prevent unauthorized access, maintain data security and use the Information collected from you in accordance with this Policy. Compete to Create has security measures in place to protect against the loss, misuse, or alteration of your Information. Despite these efforts, Compete to Create cannot guarantee that unauthorized access or disclosure of Information will never happen. If you have concerns, do not use the Products.
7. European Union Users
For Personal Data about European residents, when the purposes of processing are satisfied, and we are not required to retain Personal Data to comply with applicable law, we will delete or anonymize your Personal Data within a maximum of twelve months.
Given that the Internet is a global environment, using the Internet to collect and process Information necessarily involves the transmission of data on an international basis. Therefore, by using any of the Product(s), you acknowledge the transfer, storage or use of your Information outside your country of residence to any country (including the United States, Canada, the United Kingdom and Australia) where we have facilities or engage trusted third parties (such as payment processors, cloud service or other IT providers and other companies that provide services to us). You understand that the countries to which we may transfer Information may not have as comprehensive a level of data protection as in your country. In relation to Australia’s Privacy Act, you agree that in the case of a breach by the third party in relation to handling your personal data, we will not be accountable for the third party under the Privacy Act and you may not be able to seek redress under the Privacy Act.
Legal Basis for Use (e.g., processing) of Your Information:
You expressly grant us the right to use your Information:
· Where the use of your Information is necessary to perform our obligations under a contract with you (for example, to comply with the terms of service of our Products which you accept by browsing the Products or registering; and/or our contract to provide our Products to you);
· Where the use of your Information is necessary for our legitimate interests or the legitimate interests of others (for example, to provide security for our Products; operate our Products; make and receive payments; comply with legal requirements and defend our legal rights; prevent fraud); or
· With your consent; or
· Other grounds, as required or permitted by law in the specific respective context.
If you have any questions or complaints about Compete to Create’s privacy practices, you may contact us at the email address or mailing address set forth under “Contacting Us.” We will workto resolve the issue with you.
8. Children’s' Privacy
Generally, our Products are for users 13 years of age or older, and users must be 13 or older to create an account for a Product. For Products offered to K-12 schools, we either provide that Product without collecting, using, or disclosing “personal information” (as defined in the Children’s Online Privacy Act (“COPPA”), except as permitted by COPPA, or we obtain consent in advance of such use from the school or a parent or guardian. If we have reason to believe that any personal information has been submitted to us by a child under 13 in the United States or a child under 16 in the EU without legally-valid consent, we will take reasonable steps to delete that information as soon as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws.
9. Links to Other Websites
You may find links to third-party websites from any of the Products. These websites may have their own privacy, cookies and/or other policies, which you should check. We do not accept responsibility or liability for their policies because we have no control over them.
10. Changes to this Policy
The information practices described in this Policy are current as of the effective date at the end of this document. Compete to Create reserves the right periodically to update this Policy at its discretion. Notice of any revisions will be posted to this page and are effective once posted. If you are concerned about how your Information is used, bookmark this page and check back periodically.
11. Contacting us
If you have any questions, comments, or requests regarding this Policy, please contact us by post or email using the following contact information:
Compete to Create
ATTN: Jaime Davern
1205 E. Pike St
Seattle, WA, 98122
Email: jaime(DOT)davern (At) competetocreate.net
Please allow up to 5 business days for us to reply.