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Privacy Policy

Last revision: 9 December, 2023

 

Introduction

Pedago Holdings, Inc. (“Company”) is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the Personal Data (as defined below) we collect from users of our website, located at quantic.edu, our mobile application miya miya  ( “Application”), and our widgets (collectively, the “Site”) and services (“Services”).

 

1. Use Consent

If you are above 16 years old, by submitting Personal Data through our Site or Services, you agree to the terms of this Privacy Policy and you expressly consent to the collection, use and disclosure of your Personal Data in accordance with this Privacy Policy.

Parental consent for underage users

Most, if not all users of the Miya Miya Services are children (below 18 years of age). As such, the policy abides by the General Data Protection Regulation (GDPR) of the European Union (Regulation 2016/679).

As per point (a) of Article 6(1) of the aforementioned regulation, all personal data for children over the age of 16 can be lawfully processed.

Conditions applicable to child's consent in relation to information society services:

  1. Where point (a) of Article 6 (1) applies, in relation to the offer of information society services directly to a child, the processing of the personal data of a child shall be lawful where the child is at least 16 years old. Where the child is below the age of 16 years, such processing shall be lawful only if and to the extent that consent is given or authorized by the holder of parental responsibility over the child.

  2. Miya Miya shall make reasonable efforts to verify in such cases that consent is given or authorized by the holder of parental responsibility over the child, taking into consideration available technology.

General Data Protection Regulation (GDPR)

Processing of information collected through the services shall be lawful only if and to the extent that at least one of the following applies:

  1. the data subject has given consent to the processing of his or her personal data for one or more specific purposes;

  2. processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;

  3. processing is necessary for compliance with a legal obligation to which Miya Miya is subject;

  4. processing is necessary in order to protect the vital interests of the data subject or of another natural person;

  5. processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in Miya Miya;

  6. processing is necessary for the purposes of the legitimate interests pursued by Miya Miya or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

 

For any inquiry or concerns regarding the Privacy Policy, or about any personal information you have provided, kindly e-mail us at privacy@pedago.com

 

2. Types of Data We Collect

“Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data.

 

“Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. 

 

  1. Information You Provide to Us

  • When registering for a Miya Miya account, you (the "Student" if above 16 years old, or the "Student's Legal Guardian" if below 16 years old) agree to provide the Company with the following Personal Data to be included in our database. We may collect Personal Data from you, such as your first and last name, gender, e-mail and mailing addresses, and password when you create an account to log in to our network (“Account”).

  • If you use our Services on your mobile device, including through our Application, we may collect your phone number and the unique device id number.

  • If you tell us where you are (e.g., by allowing your mobile device to send us your location), we may store and use that information to provide you with location-based information and advertising. If you want to deactivate this feature, you can either reinstall the Application or deactivate GPS on your mobile device.

  • Our mobile homepage may let you store preferences like your location, safe search settings, and favorites. We may associate these choices with your ID or the mobile device, and you can edit these preferences at any time on our mobile homepage.

  • When connecting to our Services via a service provider that uniquely identifies your mobile device, we may receive this identification and use it to offer extended services and/or functionality.

  • Certain Services may require our collection of your phone number. We may associate that phone number to your mobile device identification information.

  • When you order Services on our Application, we will collect all information necessary to complete the transaction, including your name, credit card information, billing information and shipping information.

  • We retain information on your behalf, such as files and messages that you store using your Account.

  • If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.

  • When you post content (text, images, photographs, messages, comments or any other kind of content that is not your e-mail address) on our Site, the information contained in your posting will be stored in our servers and other users will be able to see it, along with your profile photo and any other information that you choose to make public on your public profile page (“Profile”). The information that you provide in your Profile will be visible to others if you choose to activate your profile.

  • When you post messages on the message boards of our Site, the information contained in your posting will be stored on our servers and other users will be able to see it.

  • We also collect other types of Personal Data that you provide to us voluntarily, such as your operating system and version, product registration number, and other requested information if you contact us via e-mail regarding support for the Services.

  • We may also collect Personal Data at other points in our Application that state that Personal Data is being collected.

 

2. Information Collected via Technology

  • Information Collected by Our Servers:To make our Site, Application, and Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.

  • Log Files:As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer the Site, track users’ movements around the Site, gather demographic information about our user base as a whole, and better tailor our Services to our users’ needs. For example, some of the information may be collected so that when you visit the Site or the Services again, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests. Except as noted in this Privacy Policy, we do not link this automatically-collected data to Personal Data.

  • Cookies:Like many online services, we use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs. Please see our Cookie Policy for more information.

  • Pixel Tags:In addition, we use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track online movements of Web users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages. Pixel Tags also allow us to send e-mail messages in a format users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user. We do not tie the information gathered by Pixel Tags to our users’ Personal Data.

  • Mobile Services:We may also collect non-personal information from your mobile device if you have downloaded our Application. This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include your geographic location, how you use the Application, and information about the type of device you use. In addition, in the event our Application crashes on your mobile device, we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our Application. This information is sent to us as aggregated information and is not traceable to any individual and cannot be used to identify an individual.

  • Google Analytics:We use Google Analytics to help analyze how users use the Site. Google Analytics uses Cookies to collect information such as how often users visit the Site, what pages they visit, and what other sites they used prior to coming to the Site. We use the information we get from Google Analytics only to improve our Site and Services. Google Analytics collects only the IP address assigned to you on the date you visit the Site, rather than your name or other personally identifying information. We do not combine the information generated through the use of Google Analytics with your Personal Data. Although Google Analytics plants a persistent Cookie on your web browser to identify you as a unique user the next time you visit the Site, the Cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to the Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

 

3. Location Information

If you have enabled location services on your phone, we collect your location information to make a map available to the recipients of your messages showing your location. If you do not want this information collected by us, you can disable location services on your phone.

 

4. Use of Your Personal Data

Company uses Personal Data in furtherance of our legitimate interests in operating our Application, Site and Services. More specifically:

  1. General Use: In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Data in the following ways:

    • facilitate the creation of and secure your Account on our network;

    • identify you as a user in our system;

    • provide improved administration of our Site and Services;

    • provide the Services you request;

    • improve the quality of experience when you interact with our Site and Services;

    • send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;

    • send you administrative e-mail notifications, such as security or support and maintenance advisories;

    • make telephone calls to you, from time to time, to solicit your feedback; and

    • send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of Company.

  2. User Testimonials and Feedback: We often receive testimonials and comments from users who have had positive experiences with our Services. We occasionally publish such content. When we publish this content, we may identify our users by their first and last name, and may also additional data such as their home city, professional experience, and education. We obtain the user’s consent prior to posting his or her name along with the testimonial. We may post user feedback on the Site from time to time. We will share your feedback with your first name and last initial only. If we choose to post your first and last name along with your feedback, we will obtain your consent prior to posting your name with your feedback. If you make any comments on a blog or forum associated with the Site, you should be aware that any Personal Data you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in these blogs and forums.

  3. Creation of Anonymous Data: We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. We reserve the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in our sole discretion.

 

5. Disclosure of Your Personal Data

We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.

  1. Third Parties Designated by YouWhen you use the Services, the Personal Data you provide will be shared with the third parties that you designate to receive such information, including other websites, your friends, relatives and business associates. Depending on the type of access you grant to such third parties, they may also be permitted to edit the information you have provided to us and to designate others to access and edit such information. You may change your settings at any time as to who has access to your information by contacting the Company at privacy@pedago.com. . 

  2. Users: We will share your Personal data with other Users solely for the purpose of providing the Services.

  3. Third Party Service Providers: We may share your Personal Data with third party service providers to: provide you with the Services that we offer you through our Site; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to the Company. These third party service providers are required  to not use your Personal Data other than to provide the services requested by Company.

  4. Affiliates: We may share some or all of your Personal Data with our parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy.

  5. Corporate Restructuring: We may share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.

  6. Other Disclosures: Regardless of any choices you make regarding your Personal Data (as described below), Company may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation, regulator or accreditor review; (b) to comply with relevant laws or to respond to subpoenas or warrants served on Company; (c) to protect or defend the rights or property of Company or users of the Site or Services; (d) to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements; and/or (e) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use.

 

6. Third Party Websites

Our Site may contain links to third party websites. When you click on a link to any other website or location, you will leave our Site and go to another site, and another entity may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your Personal Data after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.

 

7. Your Choices Regarding Information

The Company offers several choices and means for individuals to limit the use and disclosure of their personal data on our Service:

  1. Email Communications: We will periodically send you free newsletters and e-mails that directly promote the use of our Site or Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information below). Despite your indicated e-mail preferences, we may send you service related communications, including notices of any updates to our Terms of Use or Privacy Policy.

  2. Cookies: If you decide at any time that you no longer wish to accept Cookies from our Service for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit.. If you do not accept Cookies, however, you may not be able to use all portions of the Service or all functionality of the Service. If you have any questions about how to disable or modify Cookies, please let us know at the contact information provided below.

  3. Accessing, Changing or Deleting Your Personal Data: You may change any of your Personal Data in your Account by editing your profile within your Account or by sending an e-mail to us at privacy@pedago.com. You may request deletion of your Personal Data by us, and we will use commercially reasonable efforts to honor your request, but please note that we may be required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We may also retain your information for fraud prevention or similar purposes. You may request access to your Personal Data by sending an e-mail to us at privacy@pedago.com. We may limit or deny access to Personal Data where providing such access is unreasonably burdensome, expensive under the circumstances, or as otherwise permitted by the Data Privacy Framework Principles.

  4. ApplicationsYou can stop all collection of information by the Application by uninstalling the Application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.

 

8. Security of Your Personal Data

  • The Company is committed to protecting the security of your Personal Data. We use a variety of industry-standard security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. We also require you to enter a password to access your Account information. Please do not disclose your Account password to unauthorized people. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while Company uses reasonable efforts to protect your Personal Data, Company cannot guarantee its absolute security.

  • Please be aware that If the Company receives personal data subject to our certification under the Data Privacy Framework, and then transfers it to a third-party service provider acting as an agent on our behalf, the Company has certain liability under the Data Privacy Framework if both (i) the agent processes the personal data in a manner inconsistent with the Data Privacy Framework Principles and (ii) we are responsible for the event giving rise to the damage.

 

9. EU-U.S. Data Privacy Framework Principles and Swiss-U.S. Data Privacy Framework Principles

The Company complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. The Company has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. The Company has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/

 

10. A Note to Users Outside of the United States

If you are a non U.S. user of the Site, by visiting the Site and providing us with data, you acknowledge and agree that your Personal Data may be processed for the purposes identified in the Privacy Policy. In addition, your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country. By providing your data, you consent to such transfer.

Individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. You can usually do this using the settings and tools provided in your account, or by contacting us at privacy@pedago.com.

To the extent that the Company's processing of your Personal Data is subject to the General Data Protection Regulation, Company relies on its legitimate interests, described above, to process your data. The Company may also process other information that constitutes your Personal Data for direct marketing purposes and you have a right to object to the Company's use of your Personal Data for this purpose at any time.

 

11. Questions; Contacting Company; Reporting Violations

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Company commits to resolve DPF Principles-related complaints about our collection and use of your personal information.  EU and UK individuals and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPFshould first contact Company at the address below.

In addition, if you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, or to communicate with our Data Protection Officer, please contact us at the following address or phone number:

Address:

Pedago Holdings, Inc. 

712 H Street NE Suite 1802

Washington, DC 20002

 

Telephone:

571-483-8002

 

Email Address:

privacy@pedago.com

 

12. Data Protection Authority

VeraSafe has been appointed as Company's representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. VeraSafe can be contacted in addition to or instead of privacy@pedago.com, only on matters related to the processing of personal data. To make such an inquiry, please contact VeraSafe using this contact form: https://verasafe.com/public-resources/contact-data-protection-representative 

Alternatively, VeraSafe can be contacted at:

VeraSafe Ireland Ltd

Unit 3D North Point House

North Point Business Park

New Mallow Road

Cork T23AT2P

Ireland

 

VeraSafe Czech Republic s.r.o

Klimentská 46

Prague 1, 11002

Czech Republic

 

VeraSafe has been appointed as Company's representative in the United Kingdom for data protection matters, pursuant to Article 27 of the United Kingdom General Data Protection Regulation. If you are located within the United Kingdom, VeraSafe can be contacted in addition to or instead of privacy@quantic.edu, only on matters related to the processing of personal data. To make such an inquiry, please contact VeraSafe using this contact form: https://verasafe.com/public-resources/contact-data-protection-representative  or via telephone at +44 (20) 4532 2003.

Alternatively, VeraSafe can be contacted at:

VeraSafe United Kingdom Ltd.

37 Albert Embankment

London SE1 7TL

United Kingdom

 

13. Dispute Resolution 

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Company commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/DPF-Dispute-Resolution for more information or to file a complaint.  The services of JAMS are provided at no cost to you.

In addition, under certain conditions, individuals may invoke binding arbitration to arbitrate claims and follow the terms as set forth in Annex I of the Data Privacy Framework Principles, provided that an individual has invoked binding arbitration by delivering notice to Company following the procedures and subject to conditions set forth in Annex I of the Principles.

 

14. U.S. Federal Trade Commission Enforcement

The Company’s Data Privacy Framework compliance is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

 

15. Changes to This Privacy Policy

This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here and we will change the “Last Updated” date. You should consult this Privacy Policy regularly for any changes.

 

Resources: 

Cookie Policy

GDPR Commitment

CCPA Notice for CA Residents

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