It is always a User’s choice whether or not to provide Personal Information. However, if a User chooses not to provide requested Personal Information, that User will not be able to use certain features of the Services. We set out in detail below the information that we collect about Users and Users’ use of our Services. UME does not collect on its own behalf things like protected health information, financial information, date of birth, social security or other government-issued identification number, and other sensitive personal information.
- Collection: UME collects information about students directly from parents who are Users (“Parents”), but at present we limit this to an avatar and avatar name that we ask not be the same as the Child’s real name. In addition, Children may share information about themselves during Classes, although this is discouraged. The UME class sessions may take place over online sessions in which audio (but not video) of the Children are recorded.
- Use and Disclosure: UME may share a Child’s progress and other Service information to Educators, in order to allow the Educator to provide Classes. This information shall also be treated as part of the Parent’s Personal Data and may be shared as described in the Disclosure section above for business transfers; to vendors and service providers; and to comply with legal requirements. Children may also share information about themselves with the Educator and the rest of their class during the Class session voluntarily. While UME expects Educators and all others Users to abide by our standards of conduct, please note that we cannot control or monitor what personal information your Child shares with Educators or other classmates, nor what those third parties ultimately do with that information, and disclaim all responsibility in that regard.
- Class Audio Recordings: As described above, UME may record audio of students and Educators during UME classes (“Class Recordings”). The Class Recordings are made available by UME to the Educator of the Class and may be shared by the Educator for the entire class (and their Parents) to view (the “Permitted Recipients”). UME may also use Class Recordings to provide feedback to Educators, for customer support, and for compliance purposes. UME will obtain additional parental consent before we use any Class Recordings for promotional or other purposes. We utilize reasonable means to (i) limit the ability of Educators to create copies of the Class Recordings or to share the Class Recordings with anyone aside from Permitted Recipients, and also (ii) limit the ability of Permitted Recipients to download or re-share the Class Recordings. While we expect Educators and Permitted Recipients to abide by our standards of conduct, please note that we cannot control or monitor what such third parties ultimately do with Class Recordings, and disclaim all responsibility in that regard.
- Parental Consent: By enrolling or registering their Child for a Class, Parents are providing their parental consent for the collection of Personal data about their Child. If you as a Parent do not consent, then you should not register your Child for any Class, we will not collect, use or disclose any personal information about your Child, and your Child will not be allowed to use the Services in any way.
- Parental Choices and Controls: At any time, you can refuse to permit us to collect further Personal Data from your Children in association with your account, and can request that we delete from our records the Personal Data we have collected in connection with that account. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service. You may update your Child’s information by logging onto your account. You can contact UME to request access to, change, or delete your Child’s personal information by sending an email to us at firstname.lastname@example.org . A valid request to delete personal information will be accommodated within a reasonable time. In addition to the foregoing, we will exercise commercially reasonable efforts to delete personal information belonging to Children when it is no longer needed for the purpose for which it was collected.
- The Information We Collect About Users
We may collect, use, store and transfer different kinds of personal data about Users which we have grouped together follows:
- Identity Data means email address.
- Contact Data means email address.
- Profile Data includes Users’ profile data saved through the Service.
- Location data includes data about your geographic location while you use the App or Services.
- Technical Data includes internet protocol (IP) address, browser type and version, operating system and platform, device identifiers and pseudonymous unique identifiers.
- Usage Data includes data about how Users use our Services, such as browsing actions within the portal, the buttons, controls, Users click on, pages of our portal that Users visit, the time spent on those pages, User’s search queries, the dates and times of User’s visits, and workplace usage.
We also collect, use and share Non-personalized data called “Service Data” such as statistical or demographic data for any purpose. Service Data may be derived from User’s Personal Information but is not considered personal information in law as this information does not directly or indirectly reveal User’s identity. For example, we may aggregate User’s Usage Data to calculate the percentage of users accessing a specific Website feature.
Other than health information, we do not collect any Special Categories of Personal Data about Users (this includes details about User’s race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about User’s health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
- How Is User’s Personal Information Collected
We use different methods to collect data from and about Users including through:
- Direct interactions. Users may give us User’s Identity, Contact Health and Profile Data by registering for or using the Services and completing fields within the Services
- Automated technologies or interactions. As Users interact with our Services, we may automatically collect Technical and Usage Data about User’s equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
- Third parties or publicly available sources. We may receive Personal Information about Users from various third parties and public sources as set out below:
- Technical Data from the third parties such as the following:
1. analytics providers such as Google Analytics
2. search information providers such as Google.
- Purposes for Which We Will Use User’s Personal Information
We have set out below, in a table format, a description of all the ways we plan to use Users’ Personal Information.
To deliver the Services to Users (including by recognizing users across the devices they use, and providing, maintaining, tailoring and improving website and services)
To register Users accounts on the Services
To administer and protect our business and this the Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
To use data analytics to improve our Services, customer relationships and experiences and to personalize our Services
To make suggestions and recommendations to Users about Services that may be of interest to Users and to provide Users with information, products or services they request
To improve our Services including:
tracking email open rates, web page visits and form submissions)
a) To inform UME as to what content is effective
b) To provide follower updates
c) To personalize UME’s Services
- To third parties where you ask us to do so through the Service, or by allowing such third parties to access your account;
- To our subsidiaries and affiliates where they are providing Services.
- To contractors, service providers, and other third parties we use to support our business solely for the purpose of them providing services to us.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of UME’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by UME about our Website, App, and/or Users are among the assets transferred.
- To fulfill the purpose for which Users provide it.
- For any other purpose expressly disclosed by us when Users provide the information.
We may also disclose User’s Personal Information:
- To comply with any court order, law or legal process, including to respond to any government or regulatory request.
- To enforce or apply our Terms of Service and other agreements, including for billing and collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of UME, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Upon request, UME will provide Users with information about whether we hold any of User’s Personal Information. UME enables Users with the ability to access and correct Personal Information we have collected. If Users have any concerns or suspect unauthorized activities associated with User’s account, please contact us at help@UME.com. We will respond to User’s request within a reasonable timeframe, and in any event within 30 days of receipt of request.UME acknowledges that Users have the right to access, update, revoke permission to process, or request the deletion of User’s Personal Information. Any such query can be directed to UME’s Chief Privacy Officer at email@example.com. If requested to remove data under either scenario, we will respond within a reasonable timeframe.
- Security and Enforcement
- Retention of Data
UME will keep User’s Personal Information for as long as it remains necessary for the identified purposes set out below or as required by law, which may extend beyond the termination of our relationship with User. Users acknowledge and agree that if User request that User’s name be removed from our databases, it may not be possible to completely delete all User’s Personal Information due to legal constraints.
Identity, Contact and Profile data
- Subscription term and 3 months after account termination
- To provide the Services to you during the subscription term.
Technical and Usage data
- 3 years after account termination
- To provide the Services to you during the subscription term and to protect against fraud.
- 2 years after recording
- For compliance and risk management purposes
- Managing the Online Collection of Additional Data
As Users navigate through and interact with our Website, App and Services, we may use automatic data collection technologies to collect certain information about User’s equipment, browsing actions and patterns, location, and workplace usage patterns, including:
- Details of User’s visits to our Website or App and other communication data and the resources that Users access and use on the Website, App or account.
- Information about User’s computer and Internet connection, including User’s IP address, operating system, and browser type.
- We also may use these technologies to collect information about User’s online activities over time and across third-party websites or other online services (behavioral tracking).When Users access and use the Website, App or Services, we may automatically collect certain details of User’s access to and use of the Website, App or Services, including traffic data, location data, and other communication data and the resources that Users access and use on or through the Website, App or Services.
- We may collect information about User’s mobile device and Internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information and the device’s telephone number.
- Our Website and App collects real-time information about the location of User’s device.
We and our third-party service providers may collect information about Users in a variety of ways. We and/or our third-party partners may employ various tracking technologies, such as cookies, web beacons and analytics software, that help us better manage content on our Services by informing us what content is effective.
- Payment Processing
When you use the Services, we may ask you to pay for the use of the Services. Your payment information is processed by our third party payment service providers, and not by UME. UME does not store or have access to your financial information such as credit card numbers or bank numbers.
- Transfers and disclosures of Data
UME’s headquarters in Canada is our primary location for business operations, but may process or transfer data in or to other jurisdictions in the course of providing the Services.For example, regarding normal business operations, UME may engage a third-party to support our data storage, data processing, billing, support services, information technology, or mailings on our behalf, which third party’s facilities may be located in another jurisdiction.We may also disclose User’s Personal Information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect User’s safety, or the safety of others, investigate fraud, or respond to a government request.
- Additional Privacy Protections for Minors
We join the industry in recognizing that children, including young teens, may not be able to make informed choices about Personal Information requested online. UME does not solicit or knowingly collect Personal Information of those under the age of sixteen.
- Contact information
UME Chief Privacy Officer
UME Academy Ltd.
Updated: January 11, 2022