Effective date: 11/11/2016
Our policies apply to all visitors, Users, and others who access the Services.
BY ACCESSING THE SERVICES, REGISTERING WITH US AND/OR MAKING ANY PURCHASES, YOU SIGNIFY THAT YOU HAVE READ, UNDERSTOOD, AND CONSENT TO THE PRACTICES DESCRIBED IN THIS POLICY, INCLUDING OUR TERMS OF SERVICE AND YOUR USER AGREEMENT (IF APPLICABLE), WHICH ARE INCORPORATED HEREIN BY REFERENCE (COLLECTIVELY, THE “TERMS”). IF YOU DO NOT AGREE TO COMPLY WITH THE TERMS, YOU SHOULD NOT GIVE US ACCESS TO YOUR PERSONAL INFORMATION OR OTHER CONTENT AND SHOULD NOT USE OUR SERVICES.
Types of Information We Collect
We receive, collect and use data and other related information to better understand how TwoCan visitors use the Services, to analyze trends, administer the Services, facilitate the provision of software updates and product support, to prevent fraud, and gather broad demographic information. You agree that we may use this information to improve our Services and/or to provide services or technologies to you.
TwoCan may collect certain types of information which may be identifiable to you (collectively “Personal Information”). The information we collect may include, but is not limited to, the following:
- your name, user name, email address, and password
- Employer, Employee, or company information where applicable
- information from Third Party Services
- your contact information, such as your phone number, street address, and email address
- social media information and profiles
- your credit card information (although we may use a third party payment processor)
- billing address, if you make purchases through the Services
- live chats and customer service emails and phone calls
- order history, preferences and testimonials
- survey responses
- additional information we may require from time to time or for the purpose of authenticating yourself if we have reason to believe, in our sole discretion, that you may be violating the Terms or for any other reason we deem necessary.
Other information we may automatically collect includes, but is not limited to:
Your Content and any other data or content you contribute to or submit via the Services.
- Your profile information, including introductory statements and photos you post
- information related to Your Content and your participation in the Sessions, including video and audio recordings of the Sessions, your teacher feedback, your language competence level, homework results, test results, attendance, your Session feedback, and your communications with TwoCan.
- the name of your internet service provider
- the IP address of the computer you use to access our Services
- device information such as your hardware information, mobile provider, and device identifier, including information about the type of device and operating system you are using, device settings, and crash data
- the type of browser software you are using
- the date and time you access our Services
- referring website URLs
- the website address, if any, you leave our website and travel to
- your home page customization preferences
- search engine search terms and advertising clicks/actions
- weblogs and other clickstream data
- cookie information
- other non-personally identifiable traffic data
- Geo-location information, if you give us permission to do so
- other information about your interactions with us.
Cookies and Other Technologies
We may utilize cookies and other technologies, such as web beacons (also known as “clear gifs” and “pixel tags”) to recognize you, customize your experience, and provide advertisements. Most browsers are initially set to accept cookies. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether or not to accept it. (For some web pages that require an authorization, cookies are not optional. Users choosing not to accept cookies will probably not be able to access those pages.) We do not link cookies or web beacons to any Personal Information. However, if you expressly provide consent for TwoCan to “remember” the unique identifier that you select when you register for various Services, that unique identifier will be stored on a cookie on your computer, linked to certain credentials, and your navigation path around the Services may be tracked.
We do not currently recognize or respond to browser-initiated Do Not Track signals as there is no consistent industry standard for compliance.
Your Content/Public Content
You acknowledge and agree that any content you voluntarily disclose by participating in a Session will be shared with your TwoCan instructor and, if you participate in a group Session, with the other Users in your group. You grant us, those Users, and your TwoCan instructor a license to use Your Content as set forth in the Terms of Service.
In addition, Your Content or other content that would otherwise be considered private to you or to a limited group of people may, in some cases, be accessible by your Employer. For example, if you are an Employee whose Employer set up the Services on your behalf, information related to use of the Services, including your performance during the Sessions and the results of assessments, surveys, and tests may be shared with that Employer. If you are using TwoCan in a workplace or on a device or account issued to you by your Employer or another organization, that Employer or organization may have its own policies regarding your use of the Services. Please check with your Employer about the policies it has in place regarding your communications and related content on the Services.
When you submit Public Content, you grant us a license to use that content as set forth in the Terms of Service.
Our Use of Your Information
Our primary purpose in collecting information, both Personal Information and other, is to provide you with a safe, smooth, efficient, and customized experience. You agree that we may use such information to:
- Provide the Services to you
- Provide customer support upon request, troubleshoot problems and prevent potentially prohibited or illegal activities
- Collect fees
- Prevent potentially prohibited or illegal activities
- Customize, measure and improve our Services, content and advertising
- Perform statistical analyses, auditing and research functions
- Tell you about products, targeted marketing, updates to our Services, and promotional offers
- Monitor and enforce the Terms
- Verify your eligibility to use the certain features of the Services
Our Disclosure of Your Information
Third Party Service Providers: We share your information with certain third party service providers, including, but not limited to, Amazon Web Services, to conduct our business. For example, a third party service provider may handle credit card processing, data management, email distribution, market research, information analysis, marketing, data analytics, customer service, and promotions management. These third party service providers and other persons may also share with us information that they have independently developed or acquired. We may combine aggregate information from pixel tags, web beacons and cookies with similar data we collect from other visitors to help us improve our Services.
Agents: We may provide your Personal Information to our employees, = instructors, contractors, agents, service providers and designees (“Agents”) to enable them to perform certain services for us exclusively, including:
- payment processing
- website-related services such as web hosting
- provide and improve the Services
- maintenance services
- distribution of advertisements and other marketing materials on our behalf
Our Agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us.
Protection of ourselves and others: We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to comply with governmental requests, respond to court orders, to enforce our policies, or to protect our or others’ rights, property or safety. We may share information to prevent illegal uses of our products and Services or violations of the Terms, or to defend ourselves against third party claims. We may also share information with companies assisting in fraud protection or investigations.
Affiliated businesses: We may work with other businesses from time to time. These affiliated businesses may sell items or provide promotions to you through the Services. We may also provide services or sell products jointly with the affiliated businesses. We will notify you when an affiliated business is associated with your transaction, and we will only share Personal Information with them that is related to your transaction or otherwise necessary.
TwoCan will use all legal means to eliminate piracy of our software. As part of these efforts, TwoCan software included in the Services may include a security mechanism that can detect the installation or use of illegal or modified copies of the software, and collect and transmit data about those copies. This data collection is not designed to be performed on users of legally licensed software obtained from TwoCan or its authorized resellers. If you do not consent to the collection and transmission of such data (including to the United States), you must not use our software.
The Personal Information, Your Content and other data we collect is stored on a secure, password-protected server and only authorized personnel or third parties with whom we contract have access to your Personal Information. We use industry-standard encryption technologies with respect to the receipt and transfer of Personal Information you submit. Nevertheless, despite our best efforts, no transmission over the Internet or mobile network and no data storage method can be guaranteed to be safe 100% of the time. TwoCan CANNOT AND DOES NOT ensure or warrant the security of any information you transmit or guarantee that your Content or other data stored on the Services may not be accessed, disclosed, altered, or destroyed by breach of any of our industry standard physical, technical, or managerial safeguards. Therefore, while certain of our features employ enhanced security measures, you agree that you are solely responsible for maintaining appropriate security measures to protect Your Content and other data from unauthorized access and disclosure, and for keeping backup copies of all Your Content and other data, and to advise fellow Users to do likewise, in order to prevent catastrophic loss. TwoCan has no responsibility or liability for deletion, corruption or other damage to or loss of Your Content or other data, including, but not limited to, any content submitted, posted, or otherwise related to a Session, no matter what the cause.
When you enter sensitive information (such as a credit card number) we encrypt such information using secure socket layer technology (SSL). Your Content and other data you provide in connection with our Services are hosted on servers in the United States or in foreign jurisdictions. If you are located outside of the United States, the Personal Information you provide to us may be transferred to the United States. By submitting your Personal Information, you consent to its transfer and storage in the United States and its use in accordance with the purposes for which it was originally collected.
Your password is the key to your account. We urge to you to use unique numbers, letters and special characters, and to keep your password secure.
Deactivating Your Account
Upon your request, or in the event we terminate your account in accordance with our Terms, we will deactivate your account and remove your account from view as soon as reasonably possible, based on your account activity and in accordance with applicable law. We may retain Personal Information, Your Content, Public Content, and other data from closed accounts to the extent necessary to comply with applicable law, prevent fraud, assist with any investigations, enforce our Terms, take actions we deem necessary to protect the integrity of the Services or our Users, or take other actions otherwise permitted by law.
If you remove information that you posted to the Services, copies may remain viewable in cached and archived pages of the Services, or if your Employer, other Users or third parties using the Services have copied or saved that information.
Communications from Us
e may use your email for both transactional (e.g., order confirmation) and promotional (e.g., newsletters, special events, new product offerings, special discounts, special offers by us or other third parties) purposes. Email messages we send you may contain code that enables our database to track your usage of the emails we send you, such usage includes whether the email was opened and what links (if any) were clicked.
You may “Opt Out” of receiving most emails by sending us an email at firstname.lastname@example.org asking us to remove you from our email list. You acknowledge that it may take up to ten (10) days for us to process an opt-out request. Unsubscribing will stop you from receiving most types of communication, but it may not apply to emails about orders or transactions you place through the Services or to respond to your specific requests. If you are participating in the Sessions, you will still receive related communications even if you otherwise opt-out of our email list.
TwoCan does not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register for the Services. The Services are not directed at children under the age of 13. In the event that we learn that we have collected Personal Information from a child under age 13 without parental consent, we will delete that information as quickly as possible.
California Civil Code Section 1798.83 permits residents of the State of California to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please email us at email@example.com.
We may choose to transfer all or part of our business assets in a sale. If we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information may be one of the assets transferred to or acquired by a third party.
Changes to this Policy
If you have any questions, complaints, or claims with respect to the Services or any of the TwoCan agreements, you may contact us at firstname.lastname@example.org