HotChalk Privacy Policy and Cookies Policy

HotChalk, Inc. (“we”, “us”, “our”, or “ours”), is committed to protecting your privacy. This policy (the “Privacy Policy”), effective July 26, 2019, provides a summary of our processing of your personally identifiable information (“personal data”) through our services, such as the SHARE professional learning platform and the services we provide in connection with our university partners (collectively the “Services”); this policy will help you make informed decisions when using the Services. This Privacy Policy was developed as an extension of our commitment to combine the highest-quality academic products and services with the highest level of integrity. It is designed to assist you in understanding how we collect, use, and safeguard the personal data you provide.

1. Where are your data processed?

We operate in the United States.  Our servers, offices, and sub-processors are located in the United States and therefore personal data about you may be transferred to, stored, or processed in the United States.

2. How long are your data stored?

We limit retention of your personal data to the time necessary to fulfill the personal data’s original purpose. Your contact details and access data (defined in Section 3 below) are logged to a secure database, and analytics cookies are kept indefinitely unless you request removal. Upon a deletion request, we will retain only those copies of your personal data and any related transactions in a manner that is either (i) consistent with the law or (ii) as we believe reasonably necessary to comply with any law, regulation, legal process, or governmental request.

3. What data are collected?

We collect information about you in two ways: directly from your inputs and through automated technologies. When you use our Services, the data of the device you use to access our Services is automatically logged (“access data”). This access data includes server log files that generally consist of the following information:

  • the IP address of your computer;
  • your web browser type and version;
  • your operating system;
  • your internet service provider (ISP);
  • dates and times you accessed the Services;
  • websites visited by you prior to accessing our Services; and
  • websites you accessed from our Services
  • other user activities.

Some features of our Services require that you divulge personal data to us (e.g. search queries, entries made in forms or contracts, click data). In this case, the personal data we process that is provided by you may include:

  • contact information (address, phone, email),
  • financial information (credit card numbers, billing information, passwords),
  • biographical information (job title, company name, job history, photos); and
  • other personal data you may share with us when you contact us with requests for additional information or support.

4. Do you collect Special Categories of personal data (sensitive data)?

We DO NOT collect sensitive data (data pertaining to your race, religious or political affiliation, sexual life or orientation) and discourage you from sharing any sensitive data with us or the Services.  We will have no liability whatsoever for sensitive data and this Privacy Policy does not apply to our processing of sensitive data.

5. What cookies are used?

We use cookies to retain your preferences, account settings, and help evaluate and compile aggregated statistics about your activity.  Cookies are small text files that are saved to your computer when visiting a website. Certain cookies are deleted when you log out or end the browser session (“transient cookies” or “session cookies”). Other cookies are saved for a specific period of time (“temporary cookies”) or indefinitely (“persistent cookies”). The privacy and security settings of your browser enable you to configure the use of cookies in accordance with your preferences. You can learn more about cookies and how to block cookies on different types of browsers here or directly on your browser’s cookie support page (Internet Explorer; Firefox; Google Chrome; Safari).

In general, our use of cookies is limited to remembering that you visited our Services and the choices you made while using the Services, such as anonymous statistical information about how you use the Services, the length of your web session and the location from which you access our Services.  You may elect to disable cookies on our Services, however, choosing to do so may limit the features of the Services. The following cookies must remain active in order to use the full extent of the Services:

  • cookies that are used to identify or authenticate the user;
  • cookies used to temporarily store user input (e.g. the content of a shopping cart or online form);
  • cookies used to temporarily store marketing campaign information;
  • cookies used to store user preferences (e.g. search or language settings);
  • cookies that store data to enable the trouble-free rendering of video or audio content; and
  • analytics cookies used to record the usage behavior of our users and evaluate it in the form of statistics (e.g. advertising banners clicked, sub-pages visited, search queries conducted).

6. How are your data used?

We use your personal data in the following ways.

  • Providing the Services: we will process your personal data to activate, administer, maintain and troubleshoot the Services.
  • Processing Payments: we will process your personal data to process and fulfill requests, orders, and other e-commerce transactions.
  • Providing Technical Support: we will process your personal data to provide product and technical support for our Services.
  • Improving User Experience and the Services: we will process your personal data to (i) enhance your experience visiting the Services and delivering more individualized content; (ii) respond to your inquiries, requests and customization preferences; and (iii) identify usage trends and develop data analysis based on your usage to further develop the Services.
  • Strengthening Security and Integrity: we will process your personal data to enhance the technical and organizational measure we take to protect the security and integrity of the Services. This includes using server log files that are automatically collected and saved on a short-term basis (as described in Section 2) to perform statistical analysis of our systems to detect, prevent and stop denial-of-service attacks, troubleshoot and remedy technical issues, and prevent fraud.
  • Sending Marketing Communications: we will process your personal data to notify you about new products and services offered by us and our partners and other non-transactional information (e.g.: newsletters, push-notifications). All marketing communications will include a link with instructions to stop further communications. You can also revoke your consent to receiving electronic communication at any time by emailing the designated contact in Section 13 below and writing “Revocation – Marketing Communications” in the subject line.
  • Market Research and Advertising: we will process your personal data to (i) perform research, audits, reporting and other business operations; (ii) advertise to you and (iii) provide you with personalized content.
  • Fulfilling Legal Obligations: we will process your personal data when complying with our legal obligations brought upon by a government authority and/or to enforce our binding contractual obligations.
  • Reporting credits earned: we will report out to state and local agencies that need to track CPE credits and similar credits associated with professional development.

7. Sharing Your Data

General

We will not sell, market, rent, or otherwise distribute your personal data in ways not contemplated by this Privacy Policy.  Access to personal data is limited to a need-to-know basis that is rooted in either a legitimate purpose or to comply with legal requirements.  We possess strict internal policies that govern and limit our disclosure of personal information to third parties.  Service providers contracted by us may also be given access to your information (“contract data processors”, e.g. data centers, mailing services for newsletters, web tracking). They are bound by our directives and must provide for data security and the confidential treatment of your information under the contract data processing agreements we have concluded with them.

Newsletters

The Services provide you with the option of subscribing to our newsletter by email or chat free of charge. We collect this information and process it to send you the newsletter with the assistance of third-party service providers. Any personal data you provide in the registration form (typically email and phone number) may be shared with our third-party service providers.

Google Analytics

Our Services use Google Analytics, a service provided by Google Inc. Google Analytics creates usage profile for the users of our Services to optimize the user experience of the Services. The creation of a usage profile includes assigning a pseudonym to you and therefor using your access data to analyze your behavior and choices while using the Services.  These data are generally anonymized, and the data are not merged with other data Google, Inc. processes. For more information on data processing related to Google Analytics, refer to the Google’s privacy policy: https://policies.google.com/privacy?hl=en. You can raise an objection to the use of Google Analytics by changing your browser settings, as further described in Section 5 or by following the instructions set forth at https://tools.google.com/dlpage/gaoptout.

Heap Analytics

Our Services use Heap Analytics, a service provided by Heap, Inc.  Heap Analytics tracks user interactions with web pages and page elements such as buttons and forms. We use it to understand and improve user journeys through our Services.  For more information on data processing related to Heap Analytics, refer to their privacy policy:   https://heap.io/privacy.  You can raise an objection to the use of Heap Analytics by changing your browser settings, as further described in Section 5.

Hotjar

Our Services use Hotjar, a service provided by Hotjar Ltd.  Hotjar tracks mouse and keyboard actions by those using our Services, allowing us to identify opportunities for improving the Services’ user interface and overall user experience.  For more information on data processing related to Hotjar, refer to their privacy policy:  https://www.hotjar.com/legal/policies/privacy.  You can raise an objection to the use of Hotjar by changing your browser settings, as further described in Section 5.

8. Third party content

Our Services contain links to websites of other website operators and integrate external services from third-party service providers. By using the features and links of third-party service providers communication data are exchanged between you and the third-party service providers for technical purposes. Clicking on the links takes you to the respective websites (e.g. Facebook, YouTube). This Privacy Policy does not apply to, and we are not responsible for, third-party cookies, web beacons, or other tracking technologies, which are covered by such third parties’ privacy policies.  For more information, we encourage you to check the privacy and cookie policies of these third parties to learn about their privacy practices.

9. Profiling and automated decision-making.

We do not use any fully automated decision-making processes or profiling for any purposes that result in a significant effect on the user.

10. Your Consent.

By accessing our Services, you consent to our collection, usage and processing of your personal data and other non-personal data from the devices you use to access the Services in accordance with this Privacy Policy.

11. Children’s Personal Data.

The Services are not directed at children under that age of 16.  If we obtain actual knowledge that any information we collect has been provided by a child under the age of 16, we will promptly delete that information. If you are a minor between the ages of 13 and 18, you may use the site only in conjunction with your parent or legal guardian.

12. What data privacy rights do I have?

Subject to local data protections laws, you may have certain rights to access your personal data and limit our use and disclosure of your personal data.  To the extent required and/or permitted by the law of the applicable jurisdiction, these rights may include the following:

  • Right to Access: the right to access your personal data.
  • Right to Rectify: the right to correct any inaccuracies in your personal data.
  • Right to be Forgotten: the right to have your personal data erased.
  • Right to Restrict Processing: the right to restrict our processing of your personal data.
  • Right to Data Portability: the right to transfer your personal data to another controller to the extent that such transfer is commercially feasible.
  • Right to Object: the right to object to any processing of your personal data done by us to pursue our legitimate business interest.
  • Freedom from Automated Processing: the right to exclude yourself from automated decision making based solely on profiling and automated processes.
  • Right to Withdraw Consent: the right to take back any previously provided consent to process your personal data at any time.
  • Right to Lodge a Complaint: the right to contact the data protection authority at your place of residence and request support in pursuing your matter.

We are committed to honor these rights.  If you wish to exercise any of the rights mentioned above, please contact us and we will work with our privacy team in responding to your request and to the extent permitted and/or required by applicable laws, process your request within a reasonable time.

13. How to Contact Us.

If you provided us with personal data, you can manage how we use your personal data by either emailing or mailing us. Questions regarding this Privacy Policy or information practices should be directed to [email protected], or by regular mail:

HotChalk, Inc.
Attn: Privacy Policy
1999 S. Bascom Ave., Suite 600
Campbell, CA  95008 

14. Changes to this Privacy Policy.

We may amend this Privacy Policy from time to time by posting a revised version and updating the “Effective Date” above.  The revised version will be effective on the “Effective Date” listed.