PRIVACY POLICY
Privacy Policy
Last Updated: May 2017
Welcome to dreamroads.com, which is operated by DreamRoads, LLC (“Company,” “we,” “us” or “our”). Our Privacy Policy (this “Privacy Policy”) describes the ways in which we collect, use, and disclose information about Authorized Adult Users, Participants and Children who use an Account through dreamraods.com, and any other websites, applications and online services that link to this policy (collectively, the “Services”). By using the Services, you as an Authorized Adult User agree to the handling of information in accordance with this Privacy Policy.
In this Privacy Policy, the following defined terms shall have the meanings set forth below:
• “Adult” shall mean a person of legal age who can enter into a contract in the state in which the user resides.
• “Authorized Adult User” or “You” shall mean an Adult who establishes the Account and/or whose name(s) are entered as an “Authorized Adult User”. Every Authorized Adult User is responsible for ensuring that any Student User authorized by You to use and access the Services adheres to these Terms and the posted Privacy Policy.
• “Participant” shall mean an Adult, other than an Authorized Adult User, who is using the Account for the participant-directed learning portion of the Services, and is under the supervision of an Authorized Adult User.
• “Child” or “Children” shall mean any person under the age of 18.
• “Student Users” shall mean Children or Participants who use the participant-directed learning portion of the Services.
• Child Safe Guarantee. The Services are backed by our Child Safe guarantee. This means that when on dreamroads.com, Accounts will never include any pop-up ads or other advertisements directed at children. For the avoidance of doubt, this guarantee does not extend to any of the third-party websites that a Student User may access while accessing the Services, either through a link provided by Company or through a Student User’s exploration in order to complete assignments set forth in the Services.
• Children’s Online Privacy Protection Act (COPPA). While in most cases, Student Users will be over the age of 13, some Student Users may be under the age of 13. The Authorized Adult User establishing the Account will be asked to provide verifiable consent from the parent or legal guardian of any child under the age of 13 who will be using the Account. Company uses its best efforts to ensure that its website, and those of any third-party sites to which Student Users are referred through the Services are compliant with the Children’s Online Privacy Protection Act (www.coppa.org/comply.htm). Company does not, however, guarantee this is the case. Authorized Adult Users acknowledge this, and agree to hold Company harmless from any and all non-compliance, either known or should have been known to Company.
• Types of Users. Users of the Services include Student Users (Participants and children who use the learning portion of the Services) and Authorized Adult Users (including parents and guardians of Student Users).
• Content You Submit.
• Information Users Provide to Us. We and our third-party service providers collect any information that Authorized Adult Users and Student Users provide when using the Services, including when Authorized Adult Users create an account or contact us with a question, comment, or request, and when Student Users participate in learning activities.
• Authorized Adult Users.
When registering for and managing their Account (“Account Section” accessible via the Menu or Settings link on the Services), Authorized Adult Users are asked to provide certain information about themselves including but not limited to first and last name, email address, telephone number, physical address, billing and payment information, and relationship to Student Users. Authorized Adult Users are asked to provide certain information about Student Users who will be accessing the Services through their Account, including but not limited to first name (or nickname), last name, gender, demographic information, birthdate, phone number, school, and grade.
In addition, Authorized Adult Users can choose to provide us with information through a separate password-protected section of the Services (“Parent Section”, accessible via the Menu or Settings link on the Services) that allows Authorized Adult Users to provide testimonials, seek customer support, interact with other Authorized Adult Users, or submit comments or questions.
If you submit any information relating to other people in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
• Student Users. We encourage you to use the Services with your Student Users if you would like to monitor any content uploaded or created by them. If you would like to review all such content provided by your Student Users, this Content will be archived by the Company. Please contact Customer Service to inquire how to access this information. A fee may be assessed to access certain archived information.
• Information We Collect from Users. We and our third-party service providers collect information directly from users of the Services in the form of the actions they take and activities they complete when using the Services. For example, from Authorized Adult Users we may collect information including but not limited to demographics, patterns of usage, order history, participation in promotions or contests, referrals, answers provided on surveys and questionnaires, content provided on discussion boards, and resources accessed. From Student Users we may collect information including but not limited to patterns of usage; which activities a Student User commences and completes; when a Student User starts and stops an activity; time required to complete activities; which areas of the Services the Student User frequents; and content submitted on assignments, discussion boards, surveys, questionnaires, etc.
We and our third-party service providers also use a variety of technologies, such as cookies (small text files that the Services save on your computer or mobile device), to automatically collect certain technical information from your computer or mobile device over time and across different websites including when you use the Services, your browser type, operating system, device type, the page served, your IP address, and the websites you visited prior to visiting the Services. We and our third-party service providers may use the information collected through these technical methods for a number of purposes, including but not limited to delivering content, tracking and enhancing our users’ experience on the Services, and delivering advertising to visitors and/or users of www.dreamroads.com when they visit and/or use other websites and applications. For example, when you return to the Services after logging in, cookies help the Services recognize who you are without having to log back in. For more information, see Section 5. The information collected through these technical methods on the learning-directed portions of the Services are used only to support the internal operations of the Services. If you do not want the Services to collect information through the use of cookies, you can set your web browser to reject cookies from the Services. Each browser is different, so you should check your browser’s “Help” menu to learn how to change your cookie preferences. However, please note that if you reject or block cookies from the Services, the Services may not function as intended. For example, you may not be able to remain logged in to your Account and therefore may have to log in during each page transition.
• How We Use Information. We and our third-party service providers may use the information collected from Authorized Adult Users and Student Users as follows:
• Authorized Adult User Information. Information collected from Authorized Adult Users may be used:
• To permit you to register and use the Services, including, for example, to send you communications about Student User progress or your Account, or to allow you to make use of social media sharing through the Parent Section.
• To complete and fulfill your purchase, such as to process your payments, communicate with you regarding your purchase, and provide you with related customer service.
• To respond to your inquiries and fulfill your requests, such as to send you newsletters, retrieve your password, or provide technical support.
• To send you communications that we believe may be of interest to you, either regarding our existing or new Services, or other products/services which may interest you and your Student Users. You may always choose to stop receiving these messages, or to have Student User messages sent to you rather than to a Student User, simply by following the instructions contained in the message. You may not opt out of receiving administrative messages from us regarding your Account.
• To deliver interest-based advertising to you based on your visits to the non-learning-directed portions of the Services, including branded advertising, when you visit third-party websites and applications. We will never use information collected in the learning-directed portions of the Services for targeted advertising purposes. We do not currently respond to web browser “do not track” signals, but you may opt out of receiving online interest-based advertising from our interest-based advertising providers by visiting http://www.aboutads.info/choices. For more information about web browser “do not track” signals, visit www.allaboutdnt.org.
• To measure the effectiveness of our advertising to Authorized Adult Users.
• To allow you to participate in contests and similar promotions and to administer these activities. Some of these have rules that could contain additional details about how we use and disclose your information.
• Student User Information. Information collected from Student Users may be used:
• To adapt a Student User’s learning experience to the Student User’s needs.
• To analyze, provide progress reports on, or provide an assessment of a Student User’s performance.
• Both Authorized Adult User and Student User Information. Information collected from both Authorized Adult Users and Student Users may be used:
• To allow us to assess and improve the Services, its educational content, and other services we provide, for example, to improve our content and user experience; to research, evaluate, and improve the Services’ educational efficacy; and to inform our understanding of the Services’ user base.
• To customize, adapt, and personalize users’ viewing and content-consumption, and coaching experience, for example by analyzing a Student User’s performance in activities and adapting the Student User’s learning path to his or her needs.
• To maintain and analyze the functioning of the Services.
• As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to detect violations of and enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates, including the security of the Services; (f) to protect our rights, privacy, safety, or property, or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
• When We Disclose Information to Third Parties. Information collected from both Authorized Adult Users and Student Users may be disclosed as follows:
• To third parties who perform certain services for us including but not limited to provide learning management systems, process credit cards, develop marketing plans, or conduct or evaluate research (such as on the educational impact of the Services), provided that the service providers agree to keep the information confidential and to use it only for purposes that are permitted by this Privacy Policy.
• As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to detect violations of and enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates, including the security of the Services; (f) to protect our rights, privacy, safety, or property, or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
• Subject to confidentiality agreements, the terms of this Privacy Policy, and applicable law to, but not limited to, service providers, advisors, potential transactional partners, potential strategic partners for capital or growth, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which our assets are liquidated, sold, merged, or otherwise transferred, including in bankruptcy.
If some or all of our assets are liquidated, sold, merged, or otherwise transferred, including in bankruptcy that such acquirer shall be subject to the same commitments as stated under this Privacy Policy.
• To third-party advertising networks to collect cookie information about Authorized Adult Users’ visits to the non-learning-directed portions of the Services and to (1) deliver interest-based advertising to those Authorized Adult Users, including branded advertising, when those Authorized Adult Users visit third-party websites, and (2) provide us with statistics about the effectiveness of our advertising on third-party websites. These third-party advertising networks may use this cookie information in accordance with their own privacy policies. We do not disclose the personally identifiable information of any Student User to third parties for their marketing or promotional purposes.
• We also may disclose de-identified and/or aggregated Authorized Adult User or Student User information for any other purpose. For example, the distribution of de-identified user records to outside researchers or the distribution of reports containing aggregate user demographic and traffic patterns, provided that no individual Authorized Adult or Student User or any specific end user device can be readily identified.
• How to Access, Change, or Delete Account Information. An Authorized Adult User can review or change the information they provided when registering for the Services, including adding or removing Student Users to the Account, by updating information through the Account Section of the Services. In addition, at any time, Authorized Adult Users may contact us as described in Section 13 to request that we provide for their review, or delete from our records, any personally identifiable information they have provided about Student Users associated with their Account, or to cease collecting personally identifiable information from those Student Users. Please keep in mind that a request to delete personally identifiable information may lead to cancellation of your Account. When we change or delete any personally identifiable information at your request, we will make good faith efforts to make the changes in our databases as soon as reasonably practicable. Changing setting options may not result in immediate changes to the settings, which are subject to our operations and maintenance schedules.
All videoconferencing sessions between Participants and Company staff and/or coaches will be archived and maintained for at least six months. Such data and information may be held on our own server, or on a third-party server (such as YouTube, Google, Zoom, or that of a learning management system). If such information is stored on a server that is not Company-owned, Company will use every effort to maintain it as non-public, however, in no instance will Company be liable to any Authorized Adult User or Participant if such third-party server causes such information to become public. Authorized Adult Users should read all applicable terms and conditions and privacy policies related to such third-party servers and websites. At any time, an Authorized Adult User may ask to view an archived videoconference, which Company shall provide to Authorized Adult User within thirty (30) days of receipt of such request. Any fees incurred in retrieving such information shall be borne by the Authorized Adult User making such request.
Videotapes of Students Users and Company staff and/or coaches may be used by Company for marketing or training purposes. Every measure will be taken to not identify Student Users other than by their first names. Authorized Adult Users may specifically request that any Student Users on their Account will not be shown in any marketing or training videos by contacting Customer Support at info@dreamroads.com.
• Account Cancellation and Reactivation; Data Deletion. At any time, Authorized Adult Users may cancel their Account through the Account Section of the Services. For Accounts that have been canceled, or if the Account remains inactive for twenty-four (24) months, we will delete all personally identifiable information recorded in the “Account” section of the website for your Account. The twenty-four (24) months is provided so that you have the ability, following cancellation of an Account or inactivity, to reactivate your account and potentially recover previous information and resume where the Student User(s) left off.
Though we may seek to preserve all Student User information, including but not limited to content submitted, assignments completed, responses to surveys/questionnaires, videotapes of coaching sessions, etc. in order to allow Student Users to (1) have perpetual access to their files, and (2) resume participation in Services, we provide no guarantee, and shall have no liability or obligation to ensure, that all Student User information will be available or accessible or all learning or personalization features will be able to be recovered or resumed.
Upon Account cancellation, de-identified Authorized Adult and Student User information may nonetheless persist internally in our databases, and may still be used, on a de-identified basis, for our internal support, administrative, and record-keeping purposes including, but not limited to, allowing us to improve the Services and other services we provide through research, evaluation, and analytics.
• Links to Other Services. In certain sections of the Services, we may include links to external websites or applications. These websites and applications may be governed by their own privacy policies or information collection practices, which may be substantially different from ours. We encourage you to review the privacy policies and information collection practices of those linked websites and applications, if any, as those parties’ practices are not subject to this Privacy Policy.
• Location of Information Processing. The Services are controlled and operated by us from the United States. Your information may be stored and processed in any country where we have facilities or in which we engage service providers, including the United States, which may have data protection laws that are different from those of your country. In addition, your information may be subject to access requests from governments, courts, or law enforcement officials in countries where it may be stored or processed, under the laws of those countries.
• Security. The security of your personal information is important to us, and we employ physical, technical, and administrative security measures to safeguard the information collected by the Services. Please be aware, however, that no information system can be guaranteed to be 100% secure, so we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to the Services over networks that we do not control, including the Internet and wireless networks. If you have reason to believe that your interaction with us is not secure, please contact us as described in Section 13.
• Changes to Our Privacy Policy. If we update this Privacy Policy, we will notify you by posting the revised Privacy Policy on the Services, and for certain revisions that materially expand the ways in which we use or share the information previously collected from you through the Services either display an alert next to the Privacy Policy, display an alert upon log-in to the Services, or directly communicate with you (e.g., via the email address associated with your Account).
• Participant Communications. All communication between Participants and (1) other Participants, (2) Company staff, or (3) Company coaches will take place only within the confines of the Company website or to/from the Authorized Adult User's email account on file. NO communication outside of these authorized vehicles is permitted between Participants and other Participants or Company staff and coaches.
• Contact Us. DreamRoads, LLC, located in the United States of America, is the operator of the Services. Questions regarding this Privacy Policy and issues related to you or a Student User’s information for which you are responsible should be directed to us via any of the following methods:
Mailing address: DreamRoads, LLC
9719 E. West View Drive
Scottsdale, Arizona 85255
Attention: Andrea Keck
Telephone number: 480-620-8157
Email address: Andrea.Keck@dreamroads.com