ELLA LEARNING, INC.
Privacy policy

Welcome to the privacy policy (the “Policy”) of Ella Learning (hereafter, “Ella Learning”, “we”, “us” or “our”). We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website, www.ellalearn.com, and any of our mobile applications (collectively, the “Properties”), and will tell you about your privacy rights and how the law protects you.

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how Ella Learning collects and processes your personal data through your use of the Properties, including any data you may provide through the Properties when you, for example, create an account and interact with our services.

The Properties are intended for use by school students, including those under the age of 13. However, we do not knowingly collect data from minors.

It is important that you read this privacy policy together with our Terms of Service and any other policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

MODIFICATION

By accessing or using the Properties, you agree to be bound by the Policy. The Policy constitutes a complete agreement between you and us regarding the Properties. From time to time we may be required to change, modify, or otherwise amend this Policy and any other documents incorporated by reference herein (the “Amended Policy”). If we do so, we will provide you with reasonable advance notice, as well as receiving the prior consent from the applicable governing educational body (the “Governing Body”) before implementing the Amended Policy. You agree that we may notify you of the Amended Policy by posting them on the Properties, or communicating the Amended Policy through any method of written contact that we have established with you, and that your use of the Properties after the effective date of the Amended Policy (or engaging in such other conduct as we may reasonably specify) constitutes your agreement to the Amended Policy. Therefore, you should review this Policy and any Amended Policy before using the Properties. The Amended Policy will be effective as of the date specified in the Amended Policy, and will apply to your use of the Properties from that point forward. This Policy will govern any disputes arising before the effective date of the Amended Policy. Be sure to return to this page periodically to ensure familiarity with the most current version of this Policy.

CONTACT DETAILS

If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:

FileString, Inc. d/b/a CodeStringers
2801 Mission Street, #246
Santa Cruz, CA 95060
[email protected]

THIRD-PARTY LINKS

The Properties may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Properties, we encourage you to read the privacy policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (see “d-identified data” below).

We may collect, use, store and transfer different kinds of personal data about you in order to fulfill our requirements to the Governing Body. We have grouped such personal data as follows:

• Student Identity Data includes first name, last name, school name, unique identifier, date of birth, relationship to parent, school schedule, and school grades.
• Parent Identity Data includes first name, last name, and relationship to student.
• Teacher Identity Data includes first name, last name, school name, and school schedule.
• Contact Data includes email address.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Properties.
• Profile Data includes your username, password, and preferences.
• Usage Data includes information about how you use our Properties, products and services.
• Communications Data includes your communication preferences.

We also collect and use Di-identified Data such as statistical or demographic data, which we may use for product development, research or other purposes. Di-identified Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. If we combine or connect Di-identified Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you or the Governing Body, and you fail to provide that data when requested, we may not be able to provide our services you.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

• Direct interactions. In some cases, you may give us your personal data by filling in forms or by corresponding with us through our Properties or otherwise. This includes personal data you provide when you:
  • create an account on our Properties;
  • use the services provided through our Properties; or
  • give us feedback or contact us.
• Automated technologies or interactions. As you interact with our Properties, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from analytics providers, such as Google; and
  • Student Identity Data, Parent Identity Data, Teacher Identity Data and Contact Data from the Governing Body.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data as required to fulfill our obligations to the Governing Body, or where the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform our service with you;
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Data	Type of data	Lawful basis for processing including basis of legitimate interest
First Name / Last Name	Student Identity Data Parent Identity Data Teacher Identity Data Contact Data	To register you on the Properties To identify and communicate with you Performance of our service with you Necessary for our Legitimate Interest
Email Address	Student Identity Data Parent Identity Data Teacher Identity Data Contact Data	To register you on the Properties To communicate with you Performance of our service to you Necessary for our Legitimate Interest (to communicate with you about our service and any changes to our policies)
Date of Birth	Student Identity Data	Performance of our service to you Necessary for our Legitimate Interest
School Name	Student Identity Data Parent Identity Data Teacher Identity Data	To identify you Performance of our service to you Necessary for our Legitimate Interest
Unique Identifier	Student Identity Data	To identify you Performance of our service to you Necessary for our Legitimate Interest
Relationship to Parent	Student Identity Data Parent Identity Data	Performance of our service to the student and parent Necessary for our Legitimate Interest
Relationship to Student	Student Identity Data Parent Identity Data Teacher Identity Data	Performance of our service to the student, parent and teacher Necessary for our Legitimate Interest
School Schedule	Student Identity Data Teacher Identity Data	Performance of our service with you Necessary for our Legitimate Interest
School Grades	Student Identity Data	Performance of our service with you Necessary for our Legitimate Interest
Technical Data	Usage	To use the data in order to improve our Properties and service to you To develop and grow our business  Necessary for our Legitimate Interest (to study how our customers use our Properties, to develop it, to grow our business, and inform our strategy)

“Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

DI-IDENTIFIED DATA

We may use your Di-identified Data to:

• Develop or improve our Properties and/or services;
• Demonstrate or market the effectiveness of our Properties and/or services.

ADVERTISING AND MARKETING

We will not use Student Identify Data, Teacher Identity Data, Parent Identity Data, Profile Data or Contact Data to advertise or market products and/or services.

THIRD-PARTY MARKETING

We will not share your personal data with third parties for marketing purposes.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Properties may become inaccessible or not function properly. For more information about the cookies we use, please see.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we first receive the consent of the Governing Body, and will notify and explain to you the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the table above.

• Vendors who provide a service, including but not limited to, email communication (such as Google), and hosting and application storage platforms (such as Amazon Web Services);
• Analytics companies (such as Google);
• If we believe in good faith that we are required to do so by law, in connection with litigation, to prevent a crime, or to protect personal safety, the public, or the Properties;
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
• When we otherwise have your consent to share the information.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

DI-IDENTIFIED DATA

We will also not share Di-identified Data with a third party unless that party agrees not to attempt re-identification.

6. INTERNATIONAL TRANSFERS

The personal data we collect from you will be collected, transferred and stored in the United States. Furthermore, many of our external third parties are also based in the United States.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We conduct periodic risk assessments and remediate any identified security vulnerabilities in a timely manner. In the event of a security breach, we will promptly notify the Governing Body in accordance with our incident response plan, which is available to the Governing Body upon request. Despite our efforts, we do not guarantee the security of the Properties, our records, Student Data, or anything else. We disclaim all liability for any technical problems that we did not intentionally cause.

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as we have a contract in effect with the Governing Body and until the Governing Body asks us to delete or transfer your personal data. The foregoing notwithstanding, we may, however, retain your personal data if (a) reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirement; (b) in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you; (c) we are prohibited to delete your personal data and are required to retain it under state or federal law; or (d) we are required to store a copy as part of a disaster recovery storage system which is inaccessible to the public and which we are unable to use in the normal course of our business.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may verification and authorization of the accuracy of the new data you provide to us with the Governing Body.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that in order to comply with your request for erasure, we may need verification and authorization from the Governing Body. In some circumstances, we may also be prevented due to specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent where we are relying on consent to process your personal data and where, if applicable, we have been authorized by the Governing Body to no longer process your data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at:

FileString, Inc. d/b/a CodeStringers
2801 Mission Street, #246
Santa Cruz, CA 95060
[email protected]

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.