Updated Effective Date: July 25, 2022
OKIN Process, Inc. dba OKIN EDUCATE and its subsidiaries (collectively, “we,” “us,” or “our”) take your privacy seriously and understand the importance of protecting your Personal Information. This Privacy Policy sets forth Information about our privacy practices.
By clicking links to or visiting the websites located at www.okineducate.com and at www.okinprocess.com and other websites and mobile applications which link to this Privacy Policy (collectively, “Sites”) or using the products or services offered through this Site, you agree to this Privacy Policy, as it may be amended from time to time. This Privacy Policy is incorporated into the Terms of Use for this Site.
For Parents of Children Under the Age of 13
For any user under the age of 13 whose Personal Information we collect, we must have written consent from such user’s parent or legal guardian before we collect or use any personal information of such user on the Site. With consent, we may collect limited Personal Information from minor students only where that student’s school, district, or teacher has contracted with OKIN Educate to provide service, which contains personal Information solely for the use and benefit of the learning environment. You are welcome to contact us at info@okinprocess.com to review any Personal Information, we have collected about your child. You may request that we delete this Information or specify that we collect no more of your child’s Information. We will need to verify the identity of anyone requesting Information about a child under the age of 13 to ensure that the person is, in fact, the child’s parent or legal guardian.
If you are a parent and would like more Information on parental rights concerning a child’s educational record under the Family Educational Rights and Privacy Act (FERPA), please visit the FERPA site (http://www.ed.gov/policy/gen/guid/fpco/ferpa/index.html). If you believe that a student’s school, district, or teacher has not required parental consent before our collection of any personal information, contact us at info@okinprocess.com.
You represent and warrant that you are solely responsible for complying with the Child Online Privacy Protection Act (COPPA) requirement to secure parental consent for accessing applications that require personal Information from children under 13.
You must obtain verifiable parental consent (“Consent”) from all parents whose children will be accessing OKIN Educate and provide a copy to us upon our request. For more Information on COPPA, please see www.ftc.gov/privacy.
This policy is by the U.S. Children’s Online Privacy Protection Act (“COPPA”) and outlines our practices regarding children’s personal Information. For more Information about COPPA and general tips about protecting children’s online privacy, please visit OnGuard Online (http://www.onguardonline.gov/articles/0031-protecting-your-childs-privacy-online).
The policies outlined in this COPPA Privacy Policy are intended to supplement the Information appearing in our general Privacy Policy where the COPPA Privacy Policy conflicts with the available Privacy Policy concerning Information about a Child, the terms of this COPPA Privacy Policy will prevail over the public Privacy Policy.
Information We Collect
We collect Information through the sources described below.
Information You Provide to Us.
We collect Personal Information and non-personal Information from you (such as your or your parents’ or guardians’ name, address, email address, phone number, credit card number, school name, grade level, year of graduation, date of birth, G.P.A., test scores, academic interests, transcripts, photos, employer name, and job title, library card number, race, and military or veteran status) when you:
· Register or create an account on our Site.
· Call us.
· Purchase our products or services.
· Provide us or upload to our Site messages, documents, and other files and content during your use of our products or services.
· Enter sweepstakes or other promotions.
· Respond to surveys or questionnaires or submit testimonials.
· Please provide us with Information about events we host, sponsor, or participate in.
· Provide us Information on our Site or submit online forms so that we can contact you about products or services you may be interested in or answer questions you have; or
· When you provide us Information by other means.
Information from Third Parties.
We may collect personal and non-personal Information about you (such as your name, email address, student I.D. number, grade level, and courses you are taking) from third parties with whom we have a business relationship (such as our organizational customers, resellers, licensees, and franchisees).
We may receive Information about you from our users who refer you to us and from colleges and universities to conduct surveys.
We may obtain personal and non-personal information from publicly and commercially available sources, including organizers of events you may attend.
Information Collected Automatically.
We collect Information (such as your I.P (Intellectual Property). address, browser type, the content of any undeleted cookies that your browser previously accepted from us, the referring website address, and operating system) from your browser when you visit our Site.
Our service providers, other vendors, and our affiliates and third parties who advertise on our Site may use tracking technologies such as cookies and pixel tags to collect Information about your online interactions with our Site and our emails.
We collect Information when you purchase our products and services and use our products and services (such as recording online sessions, producing transcripts of online tutoring sessions, and tracking the drills and practice tests you take online).
Retention
We will retain your Information only for the period necessary to fulfill the purposes outlined in this Privacy Policy to provide the services unless a more extended retention period is required or permitted by law.
How We Use Information
We may use your Personal Information to:
· Provide you with and personalize our products and services.
· Create and manage your account, process your orders, and provide customer service.
· We maintain our internal records and otherwise manage our business.
· Send you newsletters and advertisements and otherwise correspond with you about products, services, events, and other organizations that we think may interest you.
· Ask for your reviews and testimonials and send you surveys and questionnaires.
· Improve our products, services, and Site.
· Develop and display content and advertising tailored to your interests on our Site and other sites, provide advertisements for our services to you, and analyze the effectiveness of our advertisements.
· Perform research and analysis about your use of or interest in our products and services and our Site and develop new products and services.
· Detect, prevent, or investigate illegal activity or misuse of our products or services and enforce our legal rights; and
· Perform functions as otherwise described to you at the time of collection.
· We may use non-personal Information for any lawful purpose.
Third Parties to whom We Disclose Information
We share your Information with third parties as described below. We do not disclose your Personal Information to third parties for their direct marketing purposes except as directed by you and as described under “Schools, You are Interested in” below.
Organizations and Persons who Arrange for Your Participation in Our Programs
We work with schools, school districts, colleges, universities, local, state, and federal government agencies, businesses, and other organizations to provide tutoring, test preparation, and college admission counseling. Your organization may arrange for your participation in these programs and negotiate a special price or trial offer or purchase (or subsidize) products or services on your behalf. We may share your personal and non-personal Information that we collect through your participation in these programs (such as test scores, transcripts or recordings of online tutoring and online class sessions, comments you leave in post-session surveys, and details regarding your usage of our programs) with the organization arranging for your access to these programs or with your parents or guardians. In addition, your school may require us to share such Information with others legally entitled to access your academic records, such as your state department of education. If you use a promotion code at our Site to create an account or add products or services, we may let the source of that promotion code know that you used that code.
Service Providers and Other Vendors
We may share your Personal Information with our service providers and other vendors, such as those who help deliver our products and services, process transactions (such as charging your credit card when you make purchases), market our products and services, obtain reviews, and testimonials, and otherwise help us operate our business.
Schools You are Interested in
You may direct the disclosure of your Personal Information to the schools on our Site for their direct marketing purposes by selecting “Request School Info” or “Request Info” next to the schools on our Site or by selecting “Select All Schools” from the search results of schools that match your interests. If you do not want to share your Personal Information with the schools, do not select the options listed above.
Licensees and Franchisees
Suppose you are located outside the United States and Canada. In that case, we may share your Personal Information with our licensees and franchisees in your location who may be providing services to you.
Affiliates
We may share your Personal Information with our affiliates to provide or improve the services.
Legally Compelled Disclosures and Safety
We may disclose Personal Information when compelled to do so by government authorities or otherwise as required or permitted by law, such as to respond to court orders and subpoenas. We may also disclose personal Information to protect the safety of others and when we have reason to believe that someone is causing injury to or interfering with our rights or property or the rights or property of others.
Business Transfer
Suppose one or more third parties acquire or all or a portion of our business because of an acquisition, merger, sale, reorganization, consolidation, or liquidation. In that case, Personal Information may be included in the transferred assets.
Authorized Disclosure
We may share your personal Information with third parties when you authorize the disclosure.
Non-Personal Information
We may share non-personal Information with any third party for any lawful purpose.
Your Access to Information
If you have an account with us, you may review and correct the Information that is accessible to you under the settings for your account on our Site or by calling (210) 966-4203.
Opting Out of Informational or Promotional Correspondence
You may elect not to receive informational or promotional correspondence from us. If you have an account with us, you may make this request under the settings for your account by indicating which correspondence you would like to receive. You can also send an email to info@okinprocess.com. In this email, please say whether: (I) you would like to opt out of receiving all email informational and promotional correspondence from us in general or (ii) if you would only like to opt out of certain of our e-newsletters or correspondence and if so which ones or (iii) you would like to opt-out of receiving SMS or text messages. You may also opt-out of our promotional emails by clicking on an opt-out link within the email you receive.
Please understand that if you opt-out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions, and communications.
Using Caution when Sharing Information with Others
When you contribute to a public area or feature of our Site, such as a chat room, bulletin board, list serve, blog, or wiki, the Information that you submit will be made available to the public. Therefore, we recommend that you do not submit any sensitive information to such areas of our Site, including your full name, home address, phone number, financial Information, or any other information that would enable other users to locate you or contact you.
Other Sites
When you are on our Site, you may be able to visit or link to other sites not operated by us. We do not control such sites and are not responsible for the information practices of these sites. This Privacy Policy does not address the information practices of those other websites, and we encourage you to read the posted privacy policies of such sites.
Security
We seek to use reasonable organizational, technical, and administrative measures to protect Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed 100% secure. If you believe your account’s security has been compromised, please immediately notify us by the “Contact Us” section below.
Nevada Privacy Rights
We do not sell the Personal Information of Nevada consumers without their authorization. Still, Nevada consumers may submit an email to info@okinprocess.com to further request that we do not sell their personal Information.
New York Privacy Rights
We do not sell or disclose the Personal Information of New York consumers without their authorization, and all personally identifiable Information of New York consumers is protected according to Part 121 of the Regulations of the Commissioner of Education. These protections include the limitation to access of personally identifiable Information to only those employees or sub-contractors who require access to provide the contracted services, not disclosing or using any personally identifiable information without the prior written consent of the consumer or eligible parent, compliance with the data security as noted in Education Law §2-d and the encryption of all data. New York consumers may submit an email to info@okinprocess.com to further request Information about our practices.
California Consumer Privacy Act Rights
The Information in this California Consumer Privacy Act Rights section applies only to California consumers. Any terms defined in the California Consumer Privacy Act of 2018 (“CCPA”) have the same meaning when used in this California Consumer Privacy Act Rights section.
Personal Information We Collect
We may collect the following categories of Personal Information:
· Identifiers (such as name, address, email, cookies, I.P. address, date of birth, student I.D. number, and library card number)
· Categories of Personal Information listed in the California Customer Records statute (such as phone number, credit card number, and education)
· Characteristics of protected classifications under California or federal law (such as military or veteran status and race)
· Commercial Information (such as purchase history)
· Internet or other electronic network activity information (such as interaction with our Sites)
· Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) (such as test scores, G.P.A., course enrollments, and transcripts)
· Audio, electronic, visual, thermal, olfactory, or similar Information (such as recorded voice, recorded video, and photos)
· Professional or employment-related Information (such as employer information and job title)
· Inferences are drawn from other categories of Personal Information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes (such as the likelihood of making a purchase based on internet or other electronic network activity).
Sources from which Personal Information is Collected
We collect Personal Information from the categories of sources listed below, as described in more detail in the “Information We Collect” section above:
· Consumers
· Schools, educational organizations, and other Third parties with whom we have a business relationship (such as our organizational customers, resellers, licensees, and franchisees)
· Other users who refer you to us
· College and universities that provide Information to conduct surveys
· Publicly and commercially available sources, including organizers of events you may attend
· Browsers and tracking technologies
· Our service providers and other vendors
Purposes for which Personal Information Will Be Used
We may use personal Information for the following purposes:
· Provide you with and personalize our products and services.
· Create and manage your account, process your orders, and provide customer service.
· We maintain our internal records and otherwise manage our business.
· Send you newsletters and advertisements and otherwise correspond with you about products, services, events, and other organizations that we think may interest you.
· Ask for your reviews and testimonials and send you surveys and questionnaires.
· Improve our products, services, and Site.
· Administer sweepstakes and other promotions.
· Develop and display content and advertising tailored to your interests on our Site and other sites, provide our advertisements to you when you visit other sites and analyze the effectiveness of our advertisements.
· Perform research and analysis about your use of or interest in our products and services, the products or services offered by others, and our Site, and develop new products and services.
· Detect, prevent, or investigate illegal activity or misuse of our products or services and enforce our legal rights; and
· Perform functions as otherwise described to you at the time of collection.
Personal Information Sold or Disclosed for a Business Purpose
We do not sell personal Information of California consumers, have not sold personal Information of California consumers in the preceding 12 months, and do not have actual knowledge of any sale of the Personal Information of minors under 16 years of age.
We may disclose personal Information to a third party for a business purpose such as providing services. We may disclose these categories of Personal Information listed below to organizations and persons who arranged for consumers’ participation in our products and services and to our service providers and other vendors:
· Identifiers
· Categories of Personal Information listed in the California Customer Records statute
· Characteristics of protected classifications under California or federal law
· Commercial Information
· Internet or other electronic network activity information
· Non-public education information
· Audio, electronic, visual, thermal, olfactory, or similar Information
· Professional or employment-related Information
· Inferences are drawn from other categories of Personal Information
Your Right to Know
You have the right to request that we disclose Information to you about our collection, use, disclosure, and sale of your Personal Information in the 12 months preceding your request. Once we receive and confirm your verifiable consumer request, then subject to exceptions provided under the CCPA and based on your request, we will disclose to you:
· The categories of personal Information we collected about you.
· The categories of sources from which we collected your personal Information.
· The business or commercial purpose for collecting or selling your personal Information.
· The categories of third parties with whom we shared your personal Information.
· The specific pieces of personal Information we collected about you.
· If we sell your Personal Information, the categories of personal Information are sold to each category of the recipient.
· If we disclose your Personal Information for a business purpose, the categories of personal Information are disclosed to each category of the recipient.
Your Right to Deletion
You have the right to request that we delete the Personal Information we have collected, subject to exceptions provided under the CCPA. Once we receive and confirm your verifiable consumer request, unless an exception applies, we will delete your personal Information from our records and direct our service providers and other vendors to delete your Personal Information from their records.
Your Right to Non-Discrimination
You have the right not to receive discriminatory treatment by us for exercising the privacy rights conferred by the CCPA.
Submitting Requests
To exercise your right to know or right to deletion described above, please submit a verifiable consumer request to us by:
· Call us at 210-966-4203; or
· Completing a contact form located at www.okineducate.com
You may make a verifiable consumer request to know twice within 12 months.
You may authorize another person as your agent to submit requests on your behalf. Unless you provide the agent with power of attorney under the California Probate Code, you will need to provide the agent with a written and signed authorization. You may also submit requests on behalf of your minor child.
Verification
We will verify your identity before fulfilling your request. If you have an account with us, we will ask you to enter your username and password through a link we provide to verify your identity. If you do not have an account with us, we will ask you to provide us with data points that we have about you to verify your identity.
Suppose you authorize another person as your agent to submit requests on your behalf. In that case, unless you provide the agent with power of attorney under the California Probate Code, we will ask the agent to provide us with the written and signed authorization that you provided to the agent. We will confirm with you that you did provide the authorization, and we will verify your identity. If you submit a request on behalf of a minor child, we will ask you to provide us with Information about your child that allows us to determine that you are the parent or guardian of the child. If the child is under the age of 13, we will ask you to sign a form declaring under penalty of lying under oath that you are the parent or guardian of the child.
Our Response to Your Request
We endeavor to respond to a verifiable consumer request within 30 days (about 4 and a half weeks) of its receipt. If we require more time (up to 45 additional days), we will inform you of the reason in writing. Our response will explain why we cannot comply with a request. We will deliver our written response by mail or electronically.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Accessibility of this Privacy Policy
Commercially available screen reader programs should be able to read this Privacy Policy. As a web page, this Privacy Policy may be printed as a document.
Users Outside of the United States
By providing personal Information to this Site, you understand and consent to the collection, maintenance, processing, and transfer of such Information in and to the United States and other countries and territories, by applicable law. We are a United States company and do not operate in or market to individuals in the European Economic Area (“EEA”). Any processing of personal data of individuals in the EEA by us is incidental. However, we recognize the rights of individuals in the EEA and, therefore, request that any individuals in the EEA who have questions about, or requests related to the personal data we collect contact us at info@okinprocess.com.
Changes to this Privacy Policy
We will update this Privacy Policy from time to time. When we post changes to this Privacy Policy, we will revise the “Effective Date” at the top of this Privacy Policy. We recommend that you check our Site from time to time to inform yourself of any changes in this Privacy Policy or other policies.
Contact Us
If you have any questions or comments regarding this Privacy Policy or our privacy practices, you may contact us by email or mail at the following address:
OKIN Educate
7965 Kennedy Hill
San Antonio, TX 78235
Attention: Legal Department