Effective Date – April 25th, 2017
Our Privacy Commitment To Our Customers
DigitalChalk follows these privacy principles both online and offline in the collection, use, sharing and security of customer information. The DigitalChalk site and staff:
- Provide you notice of our customer information practices.
- Give you choices about how your data may be used for marketing purposes.
- Provide you the opportunity to update or correct your personal information.
- Use information security safeguards.
- Limit the sharing of your information.
- Commit to complying with applicable privacy requirements.
- Provide you with means to contact us about privacy-related matters.
We value the relationship we have with our customers and are committed to responsible information-handling practices. We take great care in safeguarding your personal information and in complying with all applicable federal and state privacy laws and our own internal standards and best practices.
DigitalChalk is a subsidiary of the parent company Infinity Learning Solutions, Inc. and as such, if you provide information to any of the businesses, stores or websites owned or operated by DigitalChalk, this information may be combined or shared between current or future Infinity Learning Solutions, Inc. entities and subsidiaries. DigitalChalk operates via websites under the names DigitalChalk and Infinity Learning Solutions, Inc. as well as others.
EU-U.S. Privacy Shield
DigitalChalk and its parent company Infinity Learning Solutions, Inc participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. DigitalChalk is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List available at: https://www.privacyshield.gov/list
DigitalChalk is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. DigitalChalk complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, DigitalChalk is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, DigitalChalk may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Additionally, DigitalChalk commits to cooperate with EU data protection authorities (DPAs) and comply with the advice given by such authorities with regard to human resources data transferred from the EU in the context of an employment relationship.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at: https://feedback-form.truste.com/watchdog/request
Under certain conditions, more fully described on the Privacy Shield website at: https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint , you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
What information does DigitalChalk collect from me?
When requesting information, demonstrations, ordering or registering on our sites, as appropriate, you may be asked to enter PII such as:
- Your contact information (name, mailing address, phone number, e-mail address).
- Your billing/shipping information (credit card number, shipping address).
- Your personal preferences to help with you experience (product preferences, site preferences and likes or dislikes relating to the products we may offer).
When does DigitalChalk collect PII from me?
We collect PII from you when you request information or register on our sites, place an order, subscribe to a newsletter, fill out a form or submit a support request. When submitting PII through any of our online forms, we will identify which fields are required in order to fulfill your request.
How is my PII used?
We may use any of the PII that we collect from you during registration, making a purchase, signing up for a newsletter, in response to a survey or any marketing communication, general website review or other site features to perform certain actions such as:
- Fulfill requests for products, services or information
- Provide customer services
- Offer new products and services
- Improve the effectiveness of our websites, our marketing endeavors and our services or offers
- Conduct research and analysis
- Send marketing communications
- Perform other business activities
Does DigitalChalk share my PII with others?
DigitalChalk does not sell, trade, rent or otherwise transfer your PII to third parties. We do, however, share your PII with certain third parties such as our agents, service providers and other representatives acting on our behalf for limited purposes such as:
- Fulfilling our customers’ orders
- Sending DigitalChalk marketing communications
- Fulfilling subscription services
- Conducting research, analysis or administering surveys
- Sending regular mail and email on behalf of DigitalChalk
- Processing credit card payments
The third parties with whom we conduct business are only authorized to use your information to perform the service for which they were hired. As part of our agreement with them, they are required to follow the privacy guidelines we provide them and to take reasonable measures to ensure your personal information is secure.
From time to time, we may be required to share PII in response to a valid court order, subpoena or other legal process, governmental investigation, or as otherwise required by law. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful. We may share certain PII when we believe that such release is reasonably necessary to protect the rights, property and safety of others and ourselves. We may also transfer PII in the event of a corporate sale, merger, acquisition, dissolution or similar event.
Do I have choices regarding the use of my PII for marketing purposes?
DigitalChalk is an opt-out organization. Once we receive your PII, we may send you marketing communications that contain valuable offers, promotions and other content. You always have the ability to opt-out of receiving future marketing communications from DigitalChalk. To opt-out of receiving marketing communications from DigitalChalk, you can take one of the following actions:
- Follow the directions on a marketing e-mail or direct mail marketing communication from us. All marketing communications from DigitalChalk will tell you how to stop receiving them.
- Call 1-877-321-2451 or 1-828-398-4249 to verbally submit your request along with your current contact information.
- Send an email with your current contact information and the subject “Opt-Out” to firstname.lastname@example.org
- You may also send a request with your current contact information to: DigitalChalk Attn: Privacy Matters, Two Town Square Boulevard, Suite 242, Asheville, NC 28803
If you send an e-mail or letter request, please be sure to include your full name, address, phone number and email address and indicate specifically what type of marketing communications (e.g. e-mail, direct mail and/or phone) you wish to receive or stop receiving. This will ensure we identify you correctly in our systems and accurately process your request.
DigitalChalk will take appropriate steps to implement your request to opt-out of or opt-in to receiving marketing communications. Please note that due to production, mailing and system timelines, in order to remove you from our marketing lists, it may take up to:
- 10 business days for e-mails
- 30 days for phone calls
- 6 weeks for direct mail
Until that change takes effect, you may still receive marketing communications from us. Also, please note that even though you may have opted out of receiving marketing communications, you may still receive business-related communications such as order confirmations, product recall information or updates or other organization-related communications.
How does DigitalChalk secure and protect my PII?
Safe Purchase Policy
DigitalChalk has taken numerous steps to ensure that PII is processed confidentially, accurately and securely. The DigitalChalk websites use encryption technology, such as Secure Sockets Layer (SSL), to protect your PII during data transport. SSL encrypts ordering information such as your name, address and credit card number. Additionally, all financial transactions are processed through a gateway provider and are not stored or processed on our servers.
Choosing A Personal Password
When you create an online account on DigitalChalk, you need to select a personal password. To maximize your level of protection, you should choose at least 8-30 characters including a combination of numbers, letters and varying case. You are solely responsible for maintaining the secrecy of your password or any account information.
We may retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements.
Security Breach Notification
DigitalChalk shall give notice to each Organization Administrator when the organization’s user PII was, or it is reasonably believed to have been, inappropriately accessed as a result of a security breach. Said notice shall be made immediately upon confirmed discovery of the breach and the time necessary such as to allow DigitalChalk to determine the scope of the breach, to identify organizations and individuals affected by the breach, and to restore reasonable integrity of the data system that was breached.
If a federal, state, or local law enforcement agency determines that notice to organizations required under this policy would interfere with a criminal investigation, the notice shall be delayed upon the written request of the law enforcement agency for a specified period that the law enforcement agency determines is reasonably necessary. A law enforcement agency may, by a subsequent written request, revoke such delay as of a specified date or extend the period set forth in the original request made under this paragraph to a specified date if further delay is necessary. Notice to the affected organizations is not required if, after an appropriate investigation and consultation with relevant federal, state, or local law enforcement that it is reasonable to believe no user PII was accessed by unauthorized individuals.
Cookies And Clickstream Technology
As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site.
Third-Party Providers And Disclosure
Our websites include third-party service providers with advertising on our website to be served across the Internet. If you click on these advertisements, you will be connected to those service providers. They may collect anonymous information about your visits to our website, and your interaction with our ads. These companies may use technologies similar to those outlined above to measure the effectiveness of ads and emails. They may also use information about your visits to this and other websites so that we can provide advertisements about goods and services. We may share anonymous information with these service providers in an aggregate form, for purposes of analysis and improvement of our site. If you wish to opt out of interest-based advertising click here, or if located in the European Union click here. Please note you will continue to receive generic ads. These third-party sites have separate and independent privacy policies of which you are encouraged to review. We therefore have no responsibility or liability for the content and activities of these linked sites.
Google AdSense Advertising
Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users and can be reviewed at: https://support.google.com/adwordspolicy/answer/1316548?hl=en
We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website.
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.
Information Collected On Behalf Of Our Clients
DigitalChalk acknowledges that you have the right to access your personal information. We collect information under the direction of our Clients and have no direct relationship with the individuals whose PII we processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to the DigitalChalk’s Client (the data controller). If requested to remove data we will respond within a reasonable timeframe. We may transfer personal information to third-party service providers that help us provide our services. Transfers to subsequent third parties are covered by the service agreements with our Clients.
California Online Privacy Protection Act
According to CalOPPA, we agree to the following:
- Users can visit our site anonymously.
- You can modify your personal information by logging into your account
Handling Of Do Not Track Signals And Third-Party Behavioral Tracking
DigitalChalk does not recognize or honor browser-initiated Do Not Track (DNT) signals, plant cookies, or use advertising when a DNT browser mechanism is in place. We do not honor them because we have not implemented DNT function nor has an industry standard been adopted regarding such practices. It’s also important to note that we do not allow third-party behavioral tracking.
COPPA – Children Online Privacy Protection Act
When it comes to the collection of personal information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online. We will not knowingly or intentionally collect PII online from children under the age of 13. We are committed to protecting the privacy of children.
Can Spam Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
DigitalChalk collects your email address in order to:
- Process orders and to send information and updates pertaining to orders.
- Send you additional information related to your product and/or service
To be in accordance with the Can Spam Act, DigitalChalk agrees to the following:
- Not use false or misleading subjects or email addresses.
- Identify the message as an advertisement in some reasonable way.
- Include the physical address of our business or site headquarters.
- Monitor third-party email marketing services for compliance, if one is used.
- Honor opt-out/unsubscribe requests quickly.
- Allow users to unsubscribe by using a link at the bottom of each email.
If at any time you would like to unsubscribe from receiving future advertising or marketing emails, you can follow the instructions at the bottom of each email or email us at: email@example.com and we will promptly remove you from all advertising and marketing correspondence.
Whom should I contact if I have questions or concerns about privacy and security of my PII or if I need to update my information?
- Call: 1-877-321-2451 or 1-828-398-4249
- Send a email request to: firstname.lastname@example.org
- Mail a written request to: DigitalChalk Attn: Privacy Matters, Two Town Square Boulevard, Suite 242, Asheville, NC 28803
If you send an e-mail or mailed written request, please be sure to indicate your current information and the requested changes you would like made.