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Privacy Policy

Welcome to the Stemify Platform (“Platform”), provided by Stemify, Inc., (collectively, “STEMIFY,” “us,” “our,” and/or “we”). This privacy policy (“Privacy Policy”) is designed to assist you in understanding how we use information you provide in connection with your use of the Platform and all services provided through the Platform (collectively, “Services”) and to assist you in making informed decisions when using the same. References to “you” and “your” refer to you, a user of our Platform and/or Services.

1. LOCATION AND INTERNATIONAL TRANSFER
By accessing and/or using the Platform and/or Services, you acknowledge and agree that STEMIFY operates the Platform and provides the Services from its offices and servers located in the United States. The Platform and Services are intended solely for use within the United States. If you are using the Platform or Services from outside theUnited States, please be aware that you are sending information to the United States where our servers are located. That information may then be transferred within theUnited States or back out of the United States to other countries outside of your country of residence, depending on the type of information and how it is stored by us. These countries (including the United States) may not necessarily have data protection laws as comprehensive or protective as those in your country of residence; however, our collection, storage, and use of your information will at all times be governed by this Privacy Policy.

2.  INFORMATION WE COLLECT

2.1  Personal Information
Personal information (i.e., information that could be used to contact or identify you)(“Personal Information”) is collected when you create an account, use the Platform, and/or correspond with us (including through the Platform, by email, by text, or otherwise). Personal Information we may collect includes, but is not limited to, the following categories:

I. Contact and Demographic Information. We may collect certain student and faculty contact information when you create an account, including your first and last name, user ID, username, email address, Placement Exam Scores, enrolled courses, practice assignment progress, and progress of viewing Learning Library quizzes and answering quiz questions.

II. Direct Communications. If you communicate with us through the Platform or bye-mail, text, or otherwise, we will record the username, e-mail address, phone number, or other Personal Information from which you send your communications in order to facilitate our communications with you. Any telephone calls to and from STEMIFY may be monitored and recorded for quality assurance and training purposes.

III. Mobile Device Information. When you access and use the Platform or Services from your mobile device, we receive data from your mobile device. This may include location data, an IP address, and a device identifier.You may manage
how your mobile device and mobile browser share location information with STEMIFY, as well as how your mobile browser handles cookies and related technologies, by adjusting your mobile device privacy and security settings.Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.

IV. Personal Information from Other Sources. STEMIFY may receive PersonalInformation about you from third parties. We may associate this information with the Personal Information we collect from you. The collection, use, and disclosure of information by third parties to STEMIFY is governed by their privacy policiesApplicable to information collected from you and their agreements with STEMIFY.

V. Service Providers: We may do work with vendors, service providers, and other partners to help us provide the Service by performing tasks on our behalf. We may need to share or provide information (including personal information) to them to help them perform these business functions, These providers have limited access to your personal information to perform these tasks on our behalf, and are contractually bound to protect and use it only for the purpose for which it was disclosed and consistent with this Privacy Policy. Please see Section 11 fora list of the third parties we work with to provide the Service.

2.2 Non-Personal Information
Non-personally identifying information (“Non-Personal Information”) is information that, without the aid of additional information, cannot be directly associated with a specific person. Like most mobile Applications and online service providers, we collect Non-Personal Information about your access to and use of our Platform and Services, including referring / exit pages and URLs, computer settings, number of clicks, domain names, landing pages, pages viewed, and other such information. We collect this information through the use of cookies, pixel tags, Internet Protocol (IP) addresses, click-through URLs, domain name tracking, analytics, and other similar technologies. If you have voluntarily disclosed Personal Information to us, some or all of the Non-Personal Information may be linked to your Personal Information.

I. Cookies. Cookies are text files containing small amounts of information that are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow a website to recognize a user’s device. You can find more information about cookies at: www.allaboutcookies.org

We use cookies for a variety of purposes to improve your experience using our Platform and Services, including:

●Keeping you signed into our web content

●Understanding how you interact with web content through our Platform and Service

If you do not want to store cookies on your device, you can set your browser or device to refuse cookies or to alert you when cookies are being sent. However, some parts of the Platform and Services may not function properly if you choose not to accept cookies. If you are concerned that you have created a cookie in a previous visit, you can delete cookies that are already stored on your device by accessing your device’s cookie file.

II. Pixel Tags. Pixel tags (or clear gifs) are tiny graphics with a unique identifier, similar in function to cookies, which allow us to monitor the use of our Platform, Services, and e-mail to you, and to deliver banner advertisements to you about our products and services as you browse the Internet. Pixel tags generally work in conjunction with cookies, registering when a particular device visits a particular page. You cannot decline pixel tags; however, if you turn off cookies, pixel tag will simply detect an anonymous visit. We use pixel tags in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.

III.Internet Protocol (IP) Address. Our servers automatically identify your device by its Internet Protocol (IP) addresses. An IP address is a number that is automatically assigned to your device by your Internet Service Provider. Your IP address does not identify you by name, however, it may reveal your geographic area and your Internet Service Provider. We may match your IP address to your Personal Information.

IV. Device Profiles. We may also collect and accumulate device profile data which will help us understand and analyze the experience of our Platform and Services users. For example, we may collect data relating to the type of browser used, operating system software, screen resolution, color capability, browser plug-ins, language settings, cookie preferences, search engine keywords and JavaScript enablement.

V. Click-Through URLS. We may send you email messages with a “click-through URL” linked to the content of our website. When you click onto one of these URLs, you will pass through our server before arriving at the destination webpage. We may track this click-through data to help us determine interest in the subject matter and measure the effectiveness of our communications. You can avoid being tracked simply by not clicking on any links or images in the email.

VI. Domain Name Tracking.When you access our web content from another website, we automatically record the name of the domain from which you access the content. Additionally, if you reach our web content by means of a link from another site, our servers will note the fact that you came to us from that linked site. We may also record the domain name and URL for the next website you go to after leaving our web content.

VII. Analytics. We may use one or more third-party analytics programs including, but not limited to, Google Analytics to help analyze how users utilize our web content. Google Analytics uses its own cookies to distinguish users and to collect standard Internet log information and visitor behavior information. The information generated by the cookie about your use of our web content (includingIP address) is transmitted to Google. This information is used to create statistical reports on user activity for STEMIFY. In addition to reporting website usage statistics, Google Analytics can also be used, together with some of the advertising cookies (described above), to help show more relevant ads on Google properties (like Google Search) and across the web. For more information about Google Analytics, including opt-out options visit https://support.google.com/analytics/answer/6004245

3. OUR USE OF YOUR INFORMATION
Our primary purpose for collecting Personal Information and Non-Personal Information (collectively “User Information”) is to collect information relating to our users’ experiences with the STEMIFY Platform. We may also use your User Information for the following purposes:

  • To facilitate the creation of and secure your account
  • To identify you as a user in our system
  • To communicate with you in written, electronic, and verbal form
  • To provide information on products or services
  • To improve and optimize the Platform and Services
  • To develop new products and services
  • To send newsletters, marketing materials, and promotional offers
  • To customize the advertising and content you see
  • To verify information
  • For any other purpose disclosed at the point of collection

We may also use your User Information as necessary to comply with legal requirements, including to enforce our Terms of Use.

4. DISCLOSURE OF YOUR INFORMATION
We may share your information as follows:

4.1 Third Parties. We may share your User Information with third-party companies such as developers and partner companies for marketing purposes.

4.2  Affiliated Companies. We may share User Information with our parent company, subsidiaries and other related companies, who may use the User Information for the purposes described above.

4.3 Service Providers.  We may disclose your User Information to third-party service providers hired to perform internal business functions on our behalf including, but not limited to, providing marketing assistance, sending direct mail or email, maintaining websites or databases, providing email services, providing data analytics, and processing payments. Unless otherwise stated, these companies do not have any right to use the User Information we provide to them beyond what is necessary for them to assist us.

4.4 Legal Disclaimer Concerning Subpoenas and Other Matters. We reserve the right to release account and User Information about you when we believe, in our sole discretion, that such release is appropriate (1) to comply with the law or valid legal process; (2) to protect and defend our rights, property, safety, or other interests, including those of our parent company, subsidiaries, customers, shareholders, or others; (3) to protect against misuse or unauthorized use of our Platform or Services, including to enforce our Terms of Use and other agreements; and/or (4) to protect the personal safety or property of our users or the public.

4.5 Business Transitions. We reserve the right to transfer all User Information in our possession in the event STEMIFY goes through a business transition, such as a merger, being acquired by another company, or selling a portion of its assets. Similarly, your User Information may be passed on to a successor-in-interest in the event of a reorganization, reconstruction, liquidation, bankruptcy, or administration. We will provide you with notice of an acquisition within thirty (30) days following the completion of such a transaction, by posting on our homepage and by email to your email address that you provided to us.

5. DATA SECURITY

No transmission of data over the Internet is guaranteed to be completely secure and we cannot guarantee that your submissions through the Platform or Services will be completely secure. It may be possible for third parties to intercept or access transmissions or private communications unlawfully. Any such transmission is done at your own risk. To help protect yourself and your information, choose a unique password for our Platform, and do not use a password that you would use on any other website or online service.

If Stemify becomes aware of a systems security breach by an unauthorized party or that any user data was used for an unauthorized purpose, we will comply with relevant state and other data breach laws. We will notify users of any breach resulting in unauthorized release of data electronically, at minimum, and without unreasonable delay so that you can take appropriate steps. The notification will include date of the breach, the types of information that were subject to the breach, general description of what occurred, and steps Stemify is taking to address the breach.

6. INFORMATION CHOICES

You may opt out of receiving marketing or promotional emails from STEMIFY by following the instructions in those emails or by reviewing the settings in your account. If you opt out of receiving marketing or promotional emails, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations. You may also send requests about your Personal Information, including changes to your contact preferences, and changes to or deletions of your information or content you post, by emailing admin@stemify.ai. In some cases, we may not be able to delete your Personal Information and will retain and use your information as long as necessary to fulfill an internal business purpose, to comply with our legal obligations, to resolve disputes, and/or to enforce our Terms of Use and other agreements. You may decline to share certain data with STEMIFY, in which case we may not be able to provide you with some of the features and functionality of the Platform or Services.

7. NOTE TO CALIFORNIA RESIDENTS
7.1 Your California Privacy Rights

California Civil Code Section 1798.83 permits California residents who have provided personally identifiable information to us or our third-party advertisers and marketing partners, if any, to request certain information regarding our disclosure of personally identifiable information to third parties for direct marketing purposes. Requests should be submitted via email to admin@stemify.ai and should include CALIFORNIA PRIVACY RIGHTS in the subject line. We will need your first and last name, mailing address, and email address in order to process your request. Within thirty days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for direct marketing purposes during the immediately preceding calendar year, if any, along with the names and addresses of these third parties, if any. Please be aware that not all information sharing is covered by the requirements of Section 1798.83 and only information on covered sharing will be included in our response. This request may be made no more than once per calendar year.

7.2 DO NOT TRACK SIGNALS

Some web browsers may be configured to send Do Not Track signals to websites, or users may use similar mechanisms, to indicate a user’s preference that certain web technologies not be used to track the user’s online activity. The Platform does not accept or process such Do Not Track signals or similar mechanisms.

8. CHANGES AND UPDATES TO THIS PRIVACY POLICY

We may revise our Privacy Policy from time to time. You can see when the last update was by looking at the “Last Updated” date at the top of this page. We won’t reduce your rights under this Privacy Policy without your explicit consent. If we make any significant changes, we’ll provide prominent notice by posting a notice on the Service or the Stemify Website and notify you by email (using the email address you provided), so you can review and make sure you know about them.

We encourage you to review this Privacy Policy from time to time, to stay informed about our collection, use, and disclosure of personal information through the Service and Stemify Website. If you don’t agree with any changes to the Privacy Policy, you may terminate your account. By continuing to use the Service or the Stemify Website after the revised Privacy Policy has become effective, you acknowledge that you accept and agree to the current version of the Privacy Policy.

9. CHANGE IN CONTROL

Over time, Stemify may grow and reorganize. We may share your information, including personal information with affiliates such as a parent company, subsidiaries, joint venture partners or other companies that we control or that are under common control with us, in which case we will require those companies to agree to use your personal information in a way that is consistent with this Privacy Policy.

In the event of a change to our organizations such that all or a portion of Stemify or its assets are acquired by or merged with a third-party, or in any other situation where personal information that we have collected from users would be one of the assets transferred to or acquired by that third-party, this Privacy Policy will continue to apply to your information, and any acquirer would only be able to handle your personal information as per this policy (unless you give consent to a new policy). We will provide you with notice of an acquisition within thirty (30) days following the completion of such a transaction, by posting on our homepage and by email to your email address that you provided to us. If you do not consent to the use of your personal information by such a successor company, subject to applicable law, you may request its deletion from the company.

In the unlikely event that Stemify goes out of business, or files for bankruptcy, we will protect your personal information, and will not sell it to any third-party.

10. THIRD PARTY SERVICE PROVIDERS
Stemify Amazon Web Services (AWS):

Amazon Web Services is a subsidiary of Amazon that provides on-demand cloud computing platforms and APIs to individuals, companies, and governments, on a metered pay-as-you-go basis. The Stemify Platform is hosted by AWS and as such,AWS has access to student and faculty PII documented in Section 2.1A. For more privacy information, please see AWS Privacy Policy and/or contact Stemify’s AWS Account Representative:

Matt Visconti

MvVisco@amazon.com

646-701-6744

STEMIFY CONTACT INFORMATION

Please contact us at the following with any questions about this Privacy Policy:

STEMIFY, Inc.
400 Farmington Ave.
Farmington, CT 06032
admin@stemify.ai