PP-1 Cerebrate Privacy Policy Introduction.

Thank you for choosing Cerebrate, both your success and trust are important to the entire Cerebrate team.  We work continuously to protect your privacy and information using industry leading practices, including encryption and hashing of your username and password between your device and Cerebrate’s encrypted servers.  This means that no one can access your Cerebrate password, even if they were to access our data files.

Below you will find our privacy policy, if you have any questions after reviewing this please email Cerebrate – Privacy.

This Privacy Policy describes how we collect, protect, use, manage, process, and use your personal information so that you can use and access the Cerebrate system.  For affiliate sites and vendors, please refer to the links at the end of this document for links to these other groups’ privacy policies.

By using Cerebrate’s websites and services you consent to this privacy policy and the Cerebrate Terms of Service, a current version of the all the Terms of Service is located at https://cerebratewebsite.azurewebsites.net.

 

PP-2 Data Controller

When this policy mentions “Cerebrate”, “we”, “us” or “our” it refers to www.Cerebrate.education a part of Chickadee, Inc which is responsible for your information under this privacy policy (the “Data Controller”).

At this time, all areas are administered by Chickadee, Inc, an Arizona Corporation headquartered in Arizona.

 

PP-3 Payment Processing

At this time Cerebrate does not process payments through the cerebrate.education website or Cerebrate portal.  No payment related details are maintained on Cerebrate’s servers.  This might change in the future, in which case the Privacy Policy will be updated.

PP-4 Information We Collect

There are three general areas of information that can be collected to provide services.

Categories of information we ask and retain to provide a good user experience includes:

• Contact details, so we can communicate with you. (This does not include birthdates, credit card data, or personal addresses.) These are not shared with anyone by Cerebrate.
• School & District Details (to ensure the integrity of reporting for you, your school, and if applicable your district. If a State or regional education body provides you access, they may have access to summary information.)
• Student Information is limited to name, grade, work items and goals assigned, and teacher assessments of the work. No birthdates or other personal information is stored.
• Communication with Cerebrate for customer service and related inquiries.

None of this data is shared with third parties, unless a valid legal order is made.

 

PP-4.1 Information needed to use the Cerebrate Platform.

˙We request and collect the following personal information about you when you use the Cerebrate Platform. This information is necessary for the adequate performance of the agreement between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services.

• Account Information. When you sign up for a Cerebrate Account, we require certain information such as your first name, last name, district, school, and a work email address.
• Profile and Service Information. This information is not shared with any outside or third parties, unless via court order.
• Communications with Cerebrate and other users. When you communicate with Cerebrate or use the Cerebrate website or platform to communicate with other Members, we may collect information about your communication.

 

PP-4.2 Information you choose to give us.

You may choose to provide us with additional school, district or personal information in order to obtain a better user experience when using Cerebrate. This additional information will be processed based on your request and the resulting legitimate interest and when applicable, your consent.

• Additional Profile Information. You may choose to provide additional information as part of your Cerebrate profile (such as gender, geographic area, and a personal description). Some of this information as indicated in your Account settings is part of your profile page potentially visible to others if you post a reply to a blog post or comment on the Cerebrate website.
• Other Information. You may choose to provide us information when you fill in a form, update or add information to your Cerebrate profile, respond to surveys, post in community areas, participate in promotions, communicate with our customer care team, share your experience with us (such as CEREBRATE Stories), or use other features of CEREBRATE. Cerebrate will not share any personal details from this information with third-parties.

 

PP-4.3 Information We Automatically Collect from Your Use of the Cerebrate Platform

When you use Cerebrate we may collect personal information about the services you use and how you use them. This information is necessary for the adequate performance of the agreement between you and us, to enable us to comply with legal obligations and given our legitimate interest to provide and improve the functionalities of the Cerebrate Platform.  Unless required for fraud detection or a valid legal order, no personal details are shared with any third parties.

• Usage Information. We may collect information about your interactions with Cerebrate such as the pages or content you view, your searches, assignments you have made, and other actions on Cerebrate.
• Log Data and Device Information. We may collect log data and device information when you access and use Cerebrate. If you are not logged in the information would be limited to device and operating system and version.
  When logged in this includes, among other things: details about how you’ve used Cerebrate (including if you clicked on links to third party applications), IP address, access dates and times, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using Cerebrate
• Cookies and Similar Technologies. We use cookies and other similar technologies when you use our platform, use our mobile app, or engage with our online ads or email communications. We may collect certain information by automated means using technologies such as cookies, web beacons, pixels, browser analysis tools, server logs, and mobile identifiers. In most cases the information we collect using cookies and other tools is only used in a non-identifiable without reference to personal information. For example, we may use information we collect to better understand website traffic patterns and to optimize our website experience. In some cases, we associate the information we collect using cookies and other technology with your personal information. Our business partners may also use these tracking technologies on Cerebrate or engage others to track your behavior on our behalf.

 

PP-5 General information about data collection on the internet.

The following section (PP-5) is provided as general insights about privacy and data gathering, not about methods used by Cerebrate.

• Pixels and SDKs. Third parties, including Facebook, may use cookies, web beacons, and other storage technologies to collect or receive information from our websites and elsewhere on the internet and use that information to provide measurement services and target ads. Third-party apps, like Facebook, may collect or receive information you share to provide measurement services and targeted ads. Users can opt-out of the collection and use of information for ad targeting by updating their Facebook account ad settings and by contacting opt-out Cerebrate with a description of your request and validation information.For additional information about your choices, you may want to visit http://www.aboutads.info/choices and http://www.youronlinechoices.eu/. For more information on our use of these technologies, see our Cookie Policy.
• Do Not Track Signals. While you may disable the usage of cookies through your browser settings, CEREBRATE currently does not respond to a “Do Not Track” signal in the HTTP header from your browser or mobile application due to lack of standardization regarding how that signal should be interpreted. (For additional information see https://allaboutdnt.com/ on these issues.)

 

PP-6 Aggregated Personal Data (Personally Identifiable removed.)

Aggregated Personal Data: In an ongoing effort to better understand our Users, we might analyze the personal data in aggregate form. This aggregate information does not identify Users personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics to describe our services to current and prospective clients, business partners, and to other third parties for other lawful purposes.

PP-7 Student’s Data

Student data collection is limited on Cerebrate.  No individual Student Data is shared with third parties.  Access to Student data is restricted based on user role and role with the student.   Contact Cerebrate using the information provided under the “Contact Us” with Child’s Privacy as the Subject or Student Data Privacy.

 

PP-8 Third-Party Sites

This Privacy Policy applies only to Cerebrate, its websites, services, and applications and not to any third-party sites or companies.  While not planned, it is possible that advertisements and other links may be present in blog post comments or other areas these are beyond Cerebrate’s control.

 

PP-9 Cerebrate’s Use Of collected Information

CEREBRATE may use, store, and process personal information to (1) provide, understand, improve, and develop the CEREBRATE Platform, (2) maintain and ensure a trusted and safer environment (such as to comply with our legal obligations and ensure compliance with CEREBRATE Policies) and (3) provide, personalize, measure, and improve our customer service and outreach.

 

PP-9.1 Provide, Improve, and Develop Cerebrate

We may use the personal information to provide, improve, and develop the Cerebrate Platform and Services such as to:

• enable you to access and use Cerebrate,
• enable you to communicate with other Cerebrate users,
• operate, protect, improve, and optimize the Cerebrate Platform and experience, such as by performing analytics and conducting research,
• provide customer service,
• send you service or support messages, updates, security alerts, and account notifications,
• if you provide us with your contacts’ information, we may process this information: (i) to facilitate your referral invitations, (ii) for any purpose you authorize at the time of collection,
• to operate, protect, improve, and optimize the Cerebrate Platform and experience, and personalize and customize your experience.

 

We process this personal information for these purposes given our legitimate interest in improving Cerebrate and our Users’ experience with it, and where necessary for the adequate performance of our agreements with you and/or the school or district.

 

PP-9.2 Maintain and Ensure a Trusted and Safer Environment.

We may use personal information to create and maintain a trusted and safer environment such as to:

• Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity,
• Conduct security investigations and risk assessments,
• Comply with our legal obligations,
• Resolve disputes between Cerebrate and/or Cerebrate users and to comply with agreements with sponsoring bodies,
• Enforce Cerebrate’s Terms of Service and other policies.

We process this personal information for these purposes given our legitimate interest in protecting you and the Cerebrate Platform, to measure the adequate performance of our contracts, and to comply with applicable laws.

 

PP-10

With your consent, we may send you emails or other messages, such as newsletters, offers, hints and tips. You can opt out of receiving marketing and promotional emails by clicking the unsubscribe mechanism provided in our emails or other electronic communication. If you opt out, we may still send you non-marketing emails or other communications, which include transactional information about your accounts and our business dealings with you. If you have questions or concerns regarding this Privacy Policy, please contact us at Privacy/Marketing Question/Comment

Cerebrate will use reasonable commercial efforts to deliver the automated marketing text messages to the number you provide through compatible wireless carriers. Carriers and Cerebrate are not liable for delayed or undelivered messages. Short codes used for some Text Message Services may not be supported on all U.S. carriers.

PP-11 Sharing between Users.

To help facilitate coordination between teaching team members we may need to share certain information, including personal information, with other Users, as it is necessary for the adequate coordination, as follows:

• When you share student access with another teaching team member, such as your name and the student’s name.

We don’t share this information with uninvited parties or outside parties.

 

PP-12 Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights.

Cerebrate may disclose your information, including personal information, to courts, law enforcement, governmental authorities, tax authorities, or authorized third parties (districts), if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against Cerebrate, (iii) to respond to valid requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to enforce and administer our Terms of Service, the Payment Terms or other agreements with paying entities, or (v) to protect the rights, property or personal safety of Cerebrate, its employees, teachers, students, or members of the public.

These disclosures may be necessary to comply with our legal obligations, for the protection of your or another person’s vital interests or for the purposes of our or a third party’s legitimate interest in keeping the Cerebrate Platform secure, preventing harm or crime, enforcing, or defending legal rights, and prevention of fraud or preventing damage.

Where appropriate, Cerebrate may notify Members about legal requests unless: (i) providing notice is prohibited by the legal process itself, by a court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon Cerebrate, its Users and the Cerebrate Platform. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that User about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.

PP-13 Corporate Affiliates

To enable or support us in providing the Cerebrate Platform, we may share your information, including personal information, within our corporate family of companies that are related by common ownership or control.

• Sharing with Chickadee, Inc.even if your country of residence is not the United States, your information may be shared with Chickadee, Inc. which provides the technical infrastructure for the Cerebrate Platform, product development and maintenance, customer support, trust and safety and other business operation services. The data sharing is necessary for the performance of the agreement between you and us and is based on our legitimate interests in providing the Cerebrate Platform.

Additionally, we share your information, including personal information, with our corporate affiliates in order to support and integrate, promote, and to improve Cerebrate services.  Where possible this information is without personally identifiable details.

 

PP-14 Business Transfers

If Cerebrate undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer, or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.  Your personal information will not be sold to external marketing groups, and changes in the privacy policy would require notice and acceptance either via an active step or Opt-out option.

 

PP-15 Aggregated Data.

We may also share aggregated information (information about our users that we combine so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, research, demographic analysis, marketing, advertising, and other business purposes.

 

PP-16 Other Important Information

 

PP-16.1 Analyzing your Communications.

We may review, scan, or analyze your communications on Cerebrate for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, unacceptable use, and customer support purposes. For example, for fraud prevention efforts, we may scan and analyze messages to mask contact information and references to other websites. At times, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We may use automated methods: However, occasionally we may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of automated tools. We will not review, scan, or analyze your messaging communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications.

These activities are carried out based on Cerebrate’s legitimate interest to ensure compliance with applicable laws and our Terms of Service, preventing fraud, promoting safety, and to improve and ensure adequate performance of Cerebrate services.

 

PP-16.2 Your Rights

You may exercise any of the rights described in this section with Cerebrate by sending an email to Cerebrate – Data Control. Please note that we may ask you to verify your identity and request before taking further action on your request.

 

PP-16.3 Managing Your Information.

You may access and update much of your information through your Account settings. You are responsible for keeping your personal information and settings up to date.

 

PP-16.3 Rectification of Inaccurate or Incomplete Information.

You have the right to ask us to correct inaccurate or incomplete personal information about you (and which you cannot update yourself within your Cerebrate Account) by contacting Cerebrate – Data Control.

 

PP-16.4 Data Retention and Erasure.

We generally retain your information for as long as is necessary for the performance of the agreement between you and us and to comply with our legal obligations. In certain jurisdictions, you can request to have all your personal information deleted entirely.” Please note that if you request the erasure of your personal information:

• Cerebrate may retain personal information necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend a Cerebrate User for fraud or safety reasons, we may retain certain information from that Cerebrate Account to prevent that User from opening a new Cerebrate Account in the future.
• Cerebrate may retain and use your information necessary to comply with our legal obligations. For example, Cerebrate may keep information for tax, legal reporting and auditing obligations.
• Information you have shared with others (e.g., Reviews, forum postings) may continue to be publicly visible on the Cerebrate Platform, even after your Cerebrate Account is cancelled. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are not associated with personal identifying information.
• Because we maintain the Cerebrate Platform to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

 

PP-16.5 Withdrawing Consent and Restriction of Processing.

If Cerebrate processes your personal information based on your previous consent you may withdraw this consent by changing your Account Settings at any time or by sending a communication to CEREBRATE – Change Consent specifying which consent you are withdrawing. Please note that withdrawal of your consent does not affect the lawfulness of any processing activities based on consent prior to its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims; or (iv) you have objected to the processing of information and pending the verification whether the legitimate grounds of Cerebrate override your own.

 

PP-16.6 Objection to Processing.

In some jurisdictions, applicable law may entitle you to require Cerebrate to not process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing Cerebrate will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing, or such processing is required for the establishment, exercise, or defense of legal claims.

Where personal information is used for direct marketing purposes, you may ask Cerebrate, at any time, to cease processing your data for direct marketing purposes by sending an e-mail to Solution Center – Marketing/Privacy.

 

PP-16.7 Filing Concerns or Complaints.

You have the right to lodge complaints or concerns about our data retention by contacting Solution Center – Privacy.

 

PP-17 Rights Protected By State Law

 

PP-17.1 California & Vermont Residents

Cerebrate will not share information it collects about you with its affiliates or third parties (both financial and non-financial), except as required or permitted by your state’s law.

 

PP-17.2 California Privacy Rights

California law permits Users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those third parties. Contact Solution Center – California Privacy for such requests. Cerebrate and Cerebrate Payments do not share personal information with third parties for their own direct marketing purposes without your prior consent. Accordingly, you can prevent disclosure of your personal information to third parties for their direct marketing purposes by withholding consent.

 

PP-18

PP-19 CHANGES TO THIS PRIVACY POLICY

Cerebrate reserves the right to modify our Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on Cerebrate and update the “Last Updated” date at the top of this Privacy Policy. Cerebrate will also provide you with notice of the modification by email at least thirty (30) days before the date they become effective. If you disagree with the revised Privacy Policy, you may cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the Cerebrate will be subject to the revised Privacy Policy.

 

PP-20 CONTACT US

If you have any questions or concerns about this Privacy Policy or Cerebrate’s information handling practices, you may email us at the email addresses provided in the relevant sections above or contact us via mail at Solution Center – Privacy.

To mail a notice, you may use the following address:

CEREBRATE

12332 E Teakwood Dr

Chandler, AZ 85249

Email:

info@cerebratewebsite.azurewebsites.net