About Simple Step Learning and our Privacy Notice
Simple Step Learning, LLC ("Simple Step") feels strongly about protecting your privacy. We understand how important privacy is to you, and we are committed to creating a safe and secure environment for learners of all ages on our web site, application programming interface (our "API"), and online services (collectively, our "Website"). We use the data we collect to provide you with a better experience and fulfill our mission of providing a free, world-class education for anyone, anywhere.
Our Privacy Notice describes what information we gather from our members and others who visit and use the Website, how we use that information, and what we do to protect it. By visiting or using our Website, you expressly consent to the information handling practices described in this Privacy Notice.
Your use of the Website and any information you provide on the Website are subject to the terms of this Privacy Notice, which is incorporated into and subject to our Terms of Service. Any capitalized terms used but not defined within this Privacy Notice have the meaning given to them in our Terms of Service.
How we collect and use data
We take the information you provide to us very seriously, and we strive to put you in control of decisions around your information.
Simple Step collects the following information about you and your use of our Website:
When you register for, browse and use the Website, you may provide to Simple Step what is generally called "personally identifiable information" or "personal data" (such as your full name, email address, or a photograph of yourself) that can be used to identify you. At Simple Step, we call this data "Personal Information."
Information from Integrated Services like Facebook or Google.
If you decide to register through or otherwise grant access to a third-party social networking or integrated service (what we call an "Integrated Service"), such as Facebook Connect or Google, Simple Step may also collect Personal Information that is already associated with your Integrated Service account. You may also have the option of sharing additional information with Simple Step through an Integrated Service. If you choose to provide such information, during registration or otherwise, you are giving Simple Step the permission to use, share, and store it consistent with this Privacy Notice.
Information about your use of the Website and other User-provided Information
We may collect information about your use of certain Website features, such as the number of problems you have attempted, the number of videos you have viewed, and the amount of time spent to complete a problem. This enables us to better tailor educational experiences that are most appropriate for you.
Information obtained from other Users.
We may make available certain features on the Website that allow other Users to provide us information. This information may include Personal Information. For example, a parent may register an account for their child and provide us with certain information, such as the child's username and birthday.
To provide a personalized learning and high-quality experience for our Users, we may use various technologies that automatically record certain technical information from your browser or device, including standard log files, web beacons, or pixel tags. This technical information may include your Internet Protocol (IP) address, browser type, internet service provider (ISP), referring or exit pages, click stream data, operating system, and the dates and times that you visit the Website and assists us in understanding how our Users are using our Website.
Like most websites, whether or not you are a registered member, we may send one or more cookies – small text files containing a string of alphanumeric characters – to your computer. Cookies remember information about your activities on a website and enable us to provide you with a more personalized learning experience. Simple Step may use both session cookies and persistent cookies. A session cookie disappears automatically after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Website. You can, however, remove a persistent cookie at any time. Please review your web browser "Help" file to learn the proper way to modify your cookie settings. However, without cookies you will not have access to certain services and features on the Website.
Simple Step may use a variety of third-party service providers, such as YouTube to host our videos or Google Analytics to understand our Website usage. We may allow third-party service providers to place and read their own cookies, web beacons, and similar technologies to collect information through the Website. This information is collected directly and automatically by these third parties, and Simple Step does not participate in these data transmissions. Simple Step will, wherever feasible, contractually obligate our third-party service providers to abide by the terms of this Privacy Notice.
We may collect and store information about your location to provide you with tailored educational experiences for your region. You may be able to change the settings on your computer or mobile device to prevent it from providing us with such information.
Information from Other Sources.
In certain situations, we may obtain information, including Personal Information, from third parties or sources other than the Website. For example, if you donate to Simple Step via PayPal, we may obtain your name and mailing address to send a thank you note. If we combine or associate information from other sources with Personal Information that we collect through the Website, we will treat the combined information as Personal Information in accordance with this Privacy Notice.
Simple Step uses this information in the following ways:
To enhance our Website and the services we provide.
Simple Step uses the information you provide or that we collect to enhance our relationship with you and to operate, maintain, enhance, and provide all of the features and services found on the Website. Simple Step may, for instance, remember your recent activity so we can recommend the most appropriate content for you on your next visit. If you have given Simple Step consent, we may use your Personal Information to provide you with information about Simple Step's features, services and other offerings that may be of interest to you. Under certain circumstances, if we obtain your consent (for example, if you submit a testimonial and agree to make it public), we may post your Personal Information on the Website.
To understand how you and other Users use our Website.
Simple Step uses all of the information that you provide or that we collect from Users to understand and analyze the usage trends, learning behaviors, and preferences of our Users, to improve the way the Website works and looks, and to create new features and functionality.
To enable your participation in Simple Step partnership arrangements.
Simple Step will not share Personal Information with other third-party organizations for their marketing or promotional use without your consent or except as part of a specific program or feature for which you will have the ability to opt-in. You may ask or authorize us to share your Personal Information with authorized partners, not-for-profit organizations, and other entities that are not affiliated with Simple Step. In these cases, we will provide to these third parties only the information you have authorized or asked us to share. Simple Step may send information or offers to you on behalf of these third parties. For example, we may partner with a not-for-profit organization running a contest in your region and send you an email notifying you of the partnership; if you opt-in to the program and indicate your approval, we may share your information with the third party to facilitate your participation in the program and enable you to redeem your prize.
Limitations on Access to your Personal Information by Employees and Authorized Parties
Simple Step's employees, agents and contractors must have a legitimate business reason to access Personal Information you provide to Simple Step. We may share your Personal Information with third-party service providers, including outside contractors or agents who help us manage our information activities, but they may only use your Personal Information to provide us with a specific service and not for any other purpose. Where feasible, Simple Step will require our third-party service providers to comply with this Privacy Notice.
How we share or transfer data
Simple Step takes great care to protect the information you provide us. We do not rent or sell Personal Information that we collect from Users with third parties. We also take great measures to restrict any collection or disclosure of Personal Information from children less than 13 years of age.
Simple Step will disclose User information only as described below:
If you want information shared with other Users, we'll share it for you.
We provide certain features that may allow you to share information with other Users. For example, you may choose to populate your profile with your name, short biography, and location. Or you may ask questions that are visible to other Users of Simple Step. Whenever you share information with other Users of the Website, any Personal Information that you choose to include in, or is associated with, such User Postings will be accessible by such Users. As with most online services, once you make your Personal Information available to others in any of these ways, it may be collected and used by the recipients without restriction.
We may share data with social networks at your request.
Some of our Users choose to connect their Simple Step account with social networks. This functionality is entirely optional. If you have explicitly agreed that we may do so, Simple Step may disclose your Personal Information through a social network or similar service (like Facebook or Google). To control the information that you share, you have the option of modifying your Simple Step or social network settings or disconnecting your social network account from your Simple Step account.
We may share data with third-party applications that you authorize.
Third-party application developers and service providers (commonly known as "App Developers") may build complementary services for our platform. You may request we share your information with App Developers by connecting to the application or service and approving access to your Simple Step account. Simple Step has taken steps to try to ensure the safety of information accessed by App Developers and requires App Developers to comply with our API Terms of Service and this Privacy Notice.
We may share anonymous or aggregate data to improve our services and learn more about our Users.
In certain occasions, Simple Step may work with business partners to improve our services or offerings. We may disclose automatically collected and other aggregate non-Personal Information to authorized business partners to conduct research on online education or assist in understanding the usage, viewing, and demographic patterns for certain programs, content, services, promotions, and/or functionality on the Website.
We will share data when required by law.
Simple Step may also disclose User information if required to do so by law, or if we have a good-faith belief that such action is necessary to comply with local, state, federal, international, or other applicable laws (such as U.S. Copyright law) or respond to a court order, judicial or other government subpoena, or warrant, or administrative request. In some cases, we may make such disclosures without first providing notice to Users.
We may share data in the context of a change of business, including a merger or acquisition.
In the event that Simple Step is acquired by or merged with a third-party entity, we may transfer or assign the information that we have collected from Users as part of such merger, acquisition, sale, or other change of control.
We may share data when necessary or appropriate to protect Simple Step or others.
Simple Step may disclose information that we believe, in good faith, is appropriate or necessary to take precautions against liability; to protect Simple Step from fraudulent, abusive, or unlawful uses; to investigate and defend ourselves against any third-party claims or allegations; to assist government enforcement agencies; to protect the security or integrity of the Website; or to protect the rights, property, or personal safety of Simple Step, our Users, or others.
Your choice and options in our data collection, use, and transfer
You can choose to not provide us with Personal Information
You may always decline to share your Personal Information with Simple Step. If you do so, however, Simple Step will not be able to provide to you certain features and functionalities found on our Website. You may later enable or access those features by providing Simple Step with the necessary Personal Information.
You can edit or delete Personal Information in our records
We want you to have access to your information, so that you can help keep it as accurate as possible. If you register and provide Simple Step with Personal Information, you may update, correct, or delete it at any time by reviewing your profile information and preferences on your account settings page. If you experience any difficulties in this process, please contact us as described below.
You can disconnect us from Integrated Services
Simple Step is committed to children's privacy.
Protecting the privacy of young children is especially important to Simple Step. For that reason, we created certain features designed to help protect Personal Information relating to children who are less than 13 years of age. Simple Step does not knowingly permit any person less than 13 years of age to register directly for the Website unless Simple Step reasonably believes, or has received assurances from a Coach, that the child's parent has consented to such registration and use of the Website. If Simple Step learns that Personal Information of persons less than 13 years of age has been collected on the Website without parental consent, then Simple Step will take appropriate steps to delete this information. If you are a parent or guardian and discover that your child under the age of 13 has a registered account with the Website without your consent, please alert Simple Step at firstname.lastname@example.org and request that Simple Step delete that child's personal information from its systems.
How children may register for and use our Website:
When a child under the age of 13 ("Child User") requests to register for the Website, Simple Step will seek consent from the child's identified parent or guardian ("Parent"). During the initial registration process, if we detect the User is under the age of 13, we do not retain or use information collected from the Child User except the email address for a Parent. In some cases, basic information about a Child User may be provided to Simple Step by a Coach who has undertaken steps to obtain the appropriate consent from a Parent of the Child User.
If you are a Parent and wish to provide direct consent for your child's registration on the Website, you must first register for the Website under an adult account. Once registered, you may create a child account, request an existing child account to be assigned to the Parent account, monitor the data on a child account, or revoke a child's permission to use the Website by deleting the account.
Restrictions on Child Users:
Simple Step attempts to restrict a Child User's access to certain features that could result in disclosure by the Child User of Personal Information. For example, a Child User is not normally permitted to post public comments on the Website and may only do so with parental consent.
Some other features of the Website may, however, permit a Child User to enter free-form text through which the Child User could enter Personal Information that would be visible to other Users. This may occur, for instance, if a Child User enters personal information in answering an exercise problem or creating other projects on the Website. If you are the Parent of a Child User, please advise your Child User of the risks of posting Personal information on this Website or other online services, and that any information posted may be used by others without restriction.
Our approach to data security
Website security is important to you, and to us.
To protect your privacy and security, we take reasonable steps to verify your identity before granting you account access or making corrections to your information. We may ask you to provide certain Personal Information to confirm your identity, and may require that you create and use a password to access certain parts of the Website. You should create and maintain a strong password to help ensure the security of your account.
We try to ensure that our Website and information sent to us are safe, but no security measures are perfect.
Simple Step uses certain physical, managerial, and technical safeguards designed to preserve the integrity and security of your Personal Information and other information we maintain in connection with the Website. We cannot, however, ensure or warrant the security of any or all of the information you transmit to Simple Step, and you do so at your own risk. Once we receive your transmission of information, Simple Step makes commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
We will notify you electronically or via the Website if Simple Step experiences a data security incident that could affect you.
If we learn of a data security incident that compromises or appears to compromise your Personal Information, then we will attempt to notify you electronically so that you can take appropriate protective steps. We may also post a notice on the Website if a data security incident occurs.
How we maintain data integrity
At Simple Step, we only use Personal Information as needed for the purposes for which it was collected or where you have consented to our use of Personal Information relating to you. We take reasonable steps to ensure that the Personal Information we store and use is accurate, complete, and up-to-date. If you discover that Personal Information or other data pertaining to you is inaccurate, incomplete, or out-of-date, please update your account information or contact us as outlined below.
Links to other sites
The Website may be linked to websites operated by other entities or individuals. Some of these websites, such as our Facebook page, may be co-branded with our name or logo. This Privacy Notice does not apply to, and we cannot always control the activities of, such other third-party websites. You should consult the respective privacy policies of these third-party websites.
Our Website is operated and managed on servers located within the United States. If you choose to use our Website from the European Union or other regions of the world with laws governing data collection and use that differ from U.S. law, then you acknowledge and agree that you are transferring your Personal Information outside of those regions to the United States and that, by providing your Personal Information on the Website, you consent to that transfer.
Changes and updates to this Privacy Notice
Simple Step may modify or revise this Privacy Notice from time to time. Simple Step will notify Users of any change to our Privacy Notice by posting the revised Privacy Notice with an updated date of revision on our Website, along with a short notice of the revision posted on the Website homepage. We will not change how we use any Personal Information in any material way without also providing notice of the change via email, through this website, or through other means, and obtaining consent to any new uses.
This document was last updated on February 15, 2015