Edcor Data Services LLC - Privacy Policy

Effective Date: 10/3/2023

Overview

Edcor ("Edcor”, "we" or "us") is committed to protecting our customers' (“you”, “your”, “customer”) privacy. This Privacy Policy ("Policy") describes how Edcor collects and uses Personally Identifiable Information about you through the use of our websites, and through email, text, and other electronic communications between you and Edcor. We feel it is important that you fully understand the terms and conditions under which we use the information we gather from you through the use of our Web site located at, or linked to, the URL www.edcor.com, and through the use of any of our co-branded sites we maintain with one or more of our business partners (which web site contains a link to these terms and conditions and whose URL address contains any of the root URLs "www.edcor.com/") (our "Site").

Edcor recognizes that the EU has established strict protections regarding the handling of EU citizen’s Personally Identifiable Information, including requirements to provide adequate protection for EU Personally Identifiable Information, transferred outside of the EU. To provide adequate protection for certain EU Personally Identifiable Information, about Edcor’s customers and users received in the US, Edcor and has elected to self-certify to the EU-US Privacy Shield Framework administered by the US Department of Commerce (”Privacy Shield”). Edcor adheres to the Privacy Shield Principles of Notice, Choice, and Accountability for Onward Transfer (including accountability of to third party service providers or agents), Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability. To review Edcor’s representation on the Privacy Shield list, see the US Department of Commerce’s Privacy Shield self-certification list located at: https://www.privacyshield.gov/list.

This Policy will explain the following regarding use of each of our Site:

Data Controller, Data Protection Officer, and Representative
What Personally Identifiable Information do we collect from you?
Where do we collect information from you and how do we use it?
Who is collecting your information?
With whom do we share your information?
What are your choices regarding collection, use and distribution of your information?
What security precautions are in place to protect against the loss, misuse, or alteration of your information under our control?
Cookies/Clear GIFs.
Children, Parental Consent and Privacy.
You should carefully review privacy policies of any third-party sites accessible from any of our Site and any co-branded web sites not covered by this Policy.
Contacting us about privacy questions or concerns.
Policy changes.

This Policy applies to information we collect:

on our Site;
through our Job Agent Service;
in email, text, and other electronic messages between you and our Sites;
when you contact us by telephone, web, or fax; and,
when you interact with our advertising and applications on third-party Sites and services, if those applications or advertising include links to this policy.

This Policy does not apply to information collected:

offline or through any other means, including on any other Site operated by Edcor or any third-party (including our affiliates and subsidiaries) than www.edcor.com; or
through any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Site.

Please read this Policy carefully to understand how we will use and protect your personal information. We will not share your personal information with anyone except as described in this Policy. Changes to this Policy will be announced on our Site our site: http://www.edcor.com/privacy and will be effective immediately, so please check back periodically. Your continued use of this Site after we make changes is deemed to be acceptance of those changes, so please check this Policy periodically for updates.

1. Data Controller, Data Protection Officer, and Representative

Edcor is the data controller of the Personally Identifiable Information you provide on the Site. At this time, Edcor is not required to appoint a Data Protection Officer or a representative in the EU, and has elected not to do so. Edcor may be contacted in any manner set forth below in the Section 14 of this Privacy Policy.

2. What personally identifiable information do we collect from you?

In order to better provide you with numerous services, our Site collects several types of information about its visitors, as further explained below. Our primary goal in collecting information from you is to provide you with a smooth, efficient experience while using our Site.

Personally Identifiable Information: "Personally Identifiable Information" refers to information that lets us know the specifics of who you are and can be used to identify, contact or locate you. Personally Identifiable Information is requested when you correspond with us, or otherwise volunteer information. Personally Identifiable Information might include your name, mailing address, telephone number, email address and other identification and contact information. We generally do not request you provide and do not process any categories of Personally Identifiable Information considered sensitive under applicable EU regulations and laws. We may process some Personally Identifiable Information considered sensitive when necessary to carry out our obligations under the law, to perform special services or offerings, or to protect our legitimate interests. If we do collect EU sensitive Personally Identifiable Information, such as race, ethnicity, criminal record, sexual orientation, religious beliefs, etc., we will obtain your opt-in consent where the Privacy Shield requires, including if we disclose your sensitive Personally Identifiable Information to third parties, or before we use your sensitive EU Personally Identifiable Information for a different purpose than we collected it for or than you later authorized.

Non-Personally Identifiable Information: "Non-Personally Identifiable Information" refers to information that does not identify a specific individual by itself or in combination with other information. We gather certain information about you based upon what you view on our Site in several ways. This information is compiled and analyzed on both a personal and an aggregated basis. This information may include the Web site's Uniform Resource Locator ("URL") that you just came from, which URL you next go to, what browser you are using, and your Internet Protocol ("IP") address. A URL is the global address of documents and other resources on the World Wide Web. An IP address is an identifier for a computer or device on a Transmission Control Protocol/Internet Protocol ("TCP/IP") network, such as the World Wide Web. Networks use the TCP/IP protocol to route information based on the IP address of the destination. In other words, an IP address is a number that is automatically assigned to your computer whenever you are surfing the Web, allowing Web servers to locate and identify your computer. Computers require IP addresses in order for users to communicate on the Internet, browse, and shop.

Technical Information: “Technical Information” includes information about your internet connection, the equipment you use to access our Sites and usage details.

3. Where do we collect information from you and how do we use it?

Our primary goal in collecting personal information is to provide our visitors with a superior online experience.

We may perform statistical analyses of aggregate customer behavior. This allows us to measure relative customer interest in the various areas of our Site for product development purposes. Any information we collect is used for our own internal purposes to improve the content and navigation of our Site, to enhance users' experiences when visiting our Site, the content and/or layout of our pages, and to provide the services required by an individual customer. We also use information to notify consumers about updates to our Site, to complete user-initiated transactions.

We gather information in the following ways:

Information You, Your School, or Your Employer Provide to Us: If you contact us by telephone, web, or fax, we may keep a record of your contact information, correspondence, or comments. Information about you may also be provided to us by your school or your employer through our business relationship with them.

Automatic Collection: As you navigate the Site, you may provide some information automatically, including usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies. In conjunction with our third-party service partners, we make limited use of Cookies and Clear GIFs to gather information when you visit our Site, and when you click through to our Site from a targeted email or newsletter. To find out what Cookies and Clear GIFs are and how they can be used, please refer to Section 7 - Cookies/Clear GIFs.

Information Provided by Third-Parties: If other users or third parties send us correspondence about your activities on our Site, we may keep the information in a file specific to you.

Affiliate and Partnership Programs: You may visit sites hosted by our affiliates ("Affiliates"). Our Affiliates participate in, and provide additional and ancillary services to you (the "Program"). We may share your name, e-mail address and the value of your reimbursement, including data necessary for Affiliates to administer the Program, with a third-party service partner. We may also share such information with other third party Affiliates if you have registered with other Affiliate programs and that Affiliate has made sales for you or if such third party Affiliate directed you to our Site.

Information You Provide to Us

The information we collect on or through our Site are:

information that you provide by filling in forms on our Site. This includes information provided at the time of using our services, or requesting further services. We may also ask you for information when you enter a promotion sponsored by us, and when you report a problem with our Site;
records and copies of your correspondence (including email addresses), if you contact us;
your responses to surveys and questionnaires that we might ask you to complete;
details of transactions you carry out through our Site, including the financial information you provide; and
your search queries on the Sites;

The Personally Identifiable Information we collect from you may be required to enter into a contract with Edcor, for Edcor to perform under the contract, or to provide you with our products and services. If you refuse to provide such Personally Identifiable Information or withdraw your consent to our processing of Personally Identifiable Information, then in some cases we may not be able to enter into the contract or fulfill our obligations to you under it.

Newsletters & Promotional Emails: We may offer free electronic newsletters and promotional emails for services offered on our Site as a service to our prior customers of our Site. Through our Site, you may opt in to these newsletters and emails that periodically list current news about ourselves or you may opt in through our third-party service partners. You may opt out of receiving newsletters and promotional emails for services offered on our Site at any time. Once we have processed your request, we will not send you promotional emails with respect to services offered by us after you had opted out. There may be opportunities to subscribe to an email list that will send you information about the events on our Site, but we will only add you to the list with your consent. To stop receiving our newsletters please refer to the "opt out" feature described in Section 5 below.

With respect to our co-branded sites maintained by us in conjunction with our business partners, we may share information collected by us to our business partners under our separate agreements with them. These business partners may use your personal information to help us communicate with you about offers from us as well as offers from such partners. However, if you opt out of receiving newsletters and promotional emails from us, you will automatically opt out of receiving newsletters and promotional emails from such business partners through their use of personal information which we collected from you in our co-branded sites and which we provided to such business partners. We will ask you to share your information with such business partners via an opt-in request on such sites. Please note that with respect to personal information our third-party business partners may collect from you independent of us and outside the scope of co-branded sites maintained by us, we will have no control over the use of such information by such third-party business partners and the use and gathering of such data will be subject to the third-party's privacy policies.

Information We May Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, specifically:

details of your visits to our Sites, specifically traffic data, location data, logs, referring/exit pages, date and time of your visit to our Sites, error information, clickstream data, and other communication data and the resources that you access and use on the Sites; and
Information about your computer and internet connection, specifically your IP address, operating system, and browser type.

The information we collect automatically may be used for statistical purposes and may include Personally Identifiable Information. It helps us to improve our Sites and to deliver a better and more personalized service by enabling us to:

estimate our audience size and usage patterns;
store information about your preferences, allowing us to customize our Sites according to your individual interests;
speed up your searches; and
recognize you when you return to our Site.

More details about the automated data collection technologies and the specific cookies that we use can be found in Section 10 below.

We may share the aggregated statistics about pages viewed on our Site and other relevant information as described in this Section with third parties.

4. Who is collecting your information?

Except as otherwise expressly discussed in this Policy, only we collect your information. This Policy only addresses the use and disclosure of information we collect from you. We encourage you to ask questions and to be very cautious before you disclose your Personally Identifiable Information to others. Our third-party advertising service partner may collect information about you through the use of Cookies or Clear GIFs when you click on its advertisements, open promotional emails or newsletters or visit our Site via a link in a promotional email or newsletter. This information is gathered solely for our use.

From time to time, we may utilize the services of third-party survey providers that may collect Personally Identifiable Information from you in voluntary surveys that are conducted on our behalf. If you chose to participate in these surveys, your Personally Identifiable Information will be handled in accordance with the Policy, but your Personally Identifiable Information will remain the sole property of us and will be handled in accordance with this Policy.

5. Lawful basis for Processing your Personally Identifiable Information

We have a lawful basis for our processing of your Personally Identifiable Information, including processing for our legitimate interests (when balanced against your rights and freedoms), to fulfill our obligations to you under a contract with you, and required by law, and with your consent.

If you are in the European Union, the processing of your Personally Identifiable Information is lawful only if it is permitted under the applicable data protection laws. We have a lawful basis for each of our processing activities (except when an exception applies as described below):

Consent. By using our Site, you consent to our collection, use, and sharing of your Personally Identifiable Information as described in this privacy policy. If you do not consent to this privacy policy, please do not use the Sites;
Legitimate Interests. We will process your Personally Identifiable Information as necessary for our legitimate interests. Our legitimate interests are balanced against your rights and freedoms and we do not process your Personally Identifiable Information if your rights and freedoms outweigh our legitimate interests. Specifically, our legitimate interests are to: facilitate communication between Edcor and you; detect and correct bugs and to improve our Site; safeguard our IT infrastructure and intellectual property; detect and prevent fraud and other crime; promote and market our business; develop our product and services; and, check your financial information and perform risk assessments; and,
To Fulfill Our Obligations to You under our Contract. We process your Personally Identifiable Information in order to fulfill our obligations to you pursuant to our Contract with you, your employer, or your school to deliver our goods and services to you.
As Required by Law. We may also process your Personally Identifiable Information when we are required or permitted to by law; to comply with government inspection, audits, and other valid requests from government or other public authorities; to respond to legal process such as subpoenas; or as necessary for us to protect our interests or otherwise pursue our legal rights and remedies (for instance, when necessary to prevent or detect fraud, attacks against our network, or other criminal and tortious activities), defend litigation, and manage complaints or claims.

6. Automated Decision Making

Our processing of your Personally Identifiable Information may include automated decision making. Personally Identifiable Information that you provide to us may be used by Edcor in establishing your eligibility for benefits and tuition discounts under your employer’s tuition reimbursement program using algorithms and other automatic decision making processes.

7. With whom do we share your information?

Except as otherwise stated in this Policy, we do not sell, trade or rent your Personally Identifiable Information collected on our Site to others. The information collected by our Site is used to provide requested services, to keep you informed of services that may be of interest to you, and for statistical purposes for improving our Site. We will disclose your Personally Identifiable Information to third parties, like contractors and service providers, to deliver services, and to improve the functionality of our Site. These third parties may not use your Personally Identifiable Information other than to provide the services requested by you, your employer, your school, or us. Where required by the Privacy Shield, we enter into written agreements with those third-party agents and service providers requiring them to provide the same level of protection the Privacy Shield requires and limiting their use of the data to the specified services provided on our behalf. We take reasonable and appropriate steps to ensure that third-party agents and service providers process EU citizen’s Personally Identifiable Information in accordance with our Privacy Shield obligations and to stop and remediate any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of EU Personally Identifiable Information that we transfer to them. We do not control third parties’ collection or use of your information to serve interest based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also opt out of receiving ads from members of the NAI on its website.

From time to time and with your consent, we may disclose a very limited amount of information (names and postal addresses) to direct marketing companies for trade or rental purposes. If you provide your consent, you may opt out of this type of disclosure by following the process described in Section 5 below. We may also disclose your Personally Identifiable Information to our subsidiaries and affiliates if opt in to such practice,

We may provide aggregated statistics about our customers, sales, traffic patterns, and related Site information to third parties that do not include Personally Identifiable Information. Moreover, we may release your information when we believe that such release is reasonably necessary to enforce or apply our Terms and Conditions or to protect the rights, property, and safety of our users, others, and ourselves.

We may disclose your Personally Identifiable Information to enforce or apply our terms of use www.edcor.com/terms and other agreements; and if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Edcor, our customers, or others.

Enforcement of Law: From time to time, we may be required by law enforcement, valid national security requests or judicial authorities to provide Personally Identifiable Information to the appropriate governmental authorities. We will disclose Personally Identifiable Information upon receipt of a court order or subpoena or to cooperate with a law enforcement investigation. We fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful.

Merger and Acquisitions: In the event of a merger, consolidation, or sale or transfer of all or substantially all of the assets or business of Edcor (a "Successor"), one of the assets which would generally be transferred is the information we collect from our customers. However, the use of this information by any Successor would still be governed by the terms of this Policy, as amended from time to time, including any amendment after such transaction, and you will continue to have the right to opt-out of sharing your information with third parties.

8. Your rights regarding your information and accessing and correcting your information

Applicable data protection laws may provide you with certain rights with regards to our processing of your Personally Identifiable Information.

Access and Update. You can review and change your Personally Identifiable Information by notifying us through the methods detailed in the Section 14 of this policy. Please note that if you request access to your Personally Identifiable Information other than through our Site, you may be charged a fee subject to a maximum set by applicable law. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
Restrictions. You have the right to restrict our processing of your Personally Identifiable Information under certain circumstances. In particular, you can request we restrict our use of it if you contest its accuracy, if the processing of your Personally Identifiable Information is determined to be unlawful, or if we no longer need your Personally Identifiable Information for processing, but we have retained it as permitted by law.
Portability. To the extent the Personally Identifiable Information you provide Edcor is processed based on your consent or that we process it through automated means, you have the right to request that we provide you a copy of, or access to, all or part of such Personally Identifiable Information in structured, commonly used and machine-readable format. You also have the right to request that we transmit this Personally Identifiable Information to another controller, when technically feasible.
Withdrawal of Consent. To the extent that our processing of your Personally Identifiable Information is based on your consent, you may withdraw your consent at any time by contacting us through the methods detailed in Section 14 of this policy. Withdrawing your consent will not, however, affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your Personally Identifiable Information.
Right to be Forgotten. You have the right to request that we delete all of your Personally Identifiable Information. We cannot delete your Personally Identifiable Information except by also deleting your user account, and we will only delete your account when we no longer have a lawful basis for processing your Personally Identifiable Information or after a final determination that your Personally Identifiable Information was unlawfully processed. We may not accommodate a request to erase information if we believe the deletion would violate any law or legal requirement, if we have another lawful basis for retaining the information, or if it would cause the information to be incorrect. In all other cases, we will retain your Personally Identifiable Information as set forth in this policy. In addition, we cannot completely delete your Personally Identifiable Information as some data may rest in previous backups. These will be retained for the periods set forth in our disaster recovery policies.
Complaints. You have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. However, before doing so, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.
How You May Exercise Your Rights. You may exercise any of the above rights by contacting us through any of the methods detailed in Section 14 of this policy. If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements.

9. What security precautions are in place to protect against the loss, misuse, or alteration of your information?

We employ and surpass industry recognized information technology to protect the security of the information you submit to us. The importance of security for all Personally Identifiable Information associated with our customers is of utmost concern to us. All of the customer data we collect is protected against unauthorized access by physical security means. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personally Identifiable Information, we cannot guarantee the security of your Personally Identifiable Information transmitted to our Site. Any transmission of Personally Identifiable Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

10. Cookies

Cookies: Like many other commercial sites, our Site utilizes standard technologies called "Cookies" and Clear GIFs to collect information about how our Site is used. A Cookie is a small data text file, which a Web site stores on your computer's hard drive (if your Web browser permits) that can later be retrieved to identify you to us. Cookies were designed to help a Web site recognize a user's browser as a previous visitor and thus save and remember any preferences that may have been set while the user was browsing the site. A Cookie cannot be read by a Web site other than the one that set the Cookie. Cookies can securely store a customer's password, personalize home pages, identify which parts of a site have been visited or keep track of selections. A Cookie cannot retrieve any other data from your hard drive, pass on a computer virus, or capture your email address. No Personally Identifiable Information is recorded. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

11. Children, Parental Consent, and Privacy.

The Children's Online Privacy Protection Act took effect on April 21, 2000, and imposes certain requirements on Web sites directed toward children under 13 that collect information on those children, or on Web sites that know they are collecting Personally Identifiable Information on children under the age of 13. We want to let you know that it currently is our policy not to collect Personally Identifiable Information on any person under 16 and those under 16 are not permitted to use our Site or services on the Site, and we request that children under the age of 16 not submit any personal information to us via the Site, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn that we have inadvertently gathered Personally Identifiable Information about children under 16, we shall attempt to notify such child's parent or guardian and erase such information from our records, unless the child's parent or guardian consents to our maintaining such information. If you believe we might have any information from or about a child under 16, please contact us as set forth in Section 14 below.

12. You should carefully review privacy policies of any third-party sites accessible from any of our Site and any co-branded web sites not covered by this Policy.

Other sites accessible through our Site have their own privacy policies and data collection, use and disclosure practices. Please consult each site's privacy policy. We are not responsible for the policies or practices of third parties. Please be aware that our Site may contain links to other sites on the Internet that are owned and operated by third parties. The information practices of those sites linked to our Site are not covered by this Policy. These other sites may send their own Cookies or Clear GIFs to users, collect data, or solicit Personally Identifiable Information. Additionally, other companies which place advertising on our Site may collect information about you when you view or click on their advertising through the use of Cookies or Clear GIFs. We cannot control this collection of information. You should contact these advertisers directly if you have any questions about their use of the information that they collect.

We also may have co-branded web sites that are maintained by us in connection with one or more of our third-party business partners but which do not contain this Policy or a link to this Policy. When you submit information to one of these co-branded sites you may be submitting it to both Edcor and our third-party business partners or just to our third-party business partner. Note that these co-branded sites may contain, or link to, privacy policies that contain terms and conditions different than those contained in this Policy. Again, this Policy only pertains to the information Edcor collects and we are not responsible for the privacy policies or practices of our business partners. We encourage you to read the privacy policies of those co-branded sites so that you will always know what information we gather and what information is gathered by our third-party business partner, how each of us might use that information, to whom each of us will disclose it and what choices you have.

13. Data security.

Information transmitted over the Internet is not completely secure, but we do our best to protect your Personally Identifiable Information. You can help protect your Personally Identifiable Information and other information by keeping your password to our Sites confidential. We have implemented measures designed to secure your Personally Identifiable Information from accidental loss and from unauthorized access, use, alteration, and disclosure. These security practices include: (a) limiting access of Personally Identifiable Information to authorized personnel; (b) securing business facilities, data centers, paper files, servers, backup systems, and computing equipment, including, but not limited to, all mobile devices and other equipment with information storage capability; (c) implementing network, application, database, and platform security; (d) securing information transmission, storage, and disposal; (e) implementing authentication and access controls within media, applications, operating systems, and equipment; (f) encrypting sensitive Personally Identifiable Information stored on any media; (g) encrypting sensitive Personally Identifiable Information transmitted over public or wireless networks; (h) segregating Personally Identifiable Information from information of Edcor or its other customers so that Personally Identifiable Information is not commingled with any other types of information; (i) conducting risk assessments, penetration testing, and vulnerability scans and promptly implementing a corrective action plan to correct any issues that are reported as a result of the testing; (j) implementing secure software development and change management best practices, (k) implementing appropriate personnel security and integrity procedures and practices, including, but not limited to, conducting background checks consistent with applicable law; and, (l) providing appropriate privacy and information security training to Edcor’s employees.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Site like message boards. The information you share in public areas may be viewed by any user of the Site.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personally Identifiable Information, we cannot guarantee the security of your Personally Identifiable Information transmitted to our Site. Any transmission of Personally Identifiable Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

14. Contacting us about privacy questions or concerns.

If you have any questions about this Policy, requests related to your Personally Identifiable Information, the practices of our Site, or your dealings with our Site, please contact us at www.Edcor.com click on Contact Us.

15. Policy changes.

If we make changes to any terms or conditions of the Policy, the changes will be posted on this portion of the Site so that you will always know what information we gather, how we might use that information, to whom we will disclose it and what choices you have. If we make material changes to how we treat our users’ Personally Identifiable Information, we will notify you by through a notice on the Sites’ home page. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Sites and this Privacy Policy to check for any changes

Appendix

A.1 For Individuals Based in the European Economic Area (EEA), United Kingdom (UK) and Switzerland

If you are a resident of the European Economic Area (“EEA”), in order to provide our Sites, products, and services to you, we may send and store your Personally Identifiable Information outside of the EEA, including to the United States. Accordingly, your Personally Identifiable Information may be transferred outside the country where you reside or are located, including to countries that may not or do not provide an adequate level of protection for your Personally Identifiable Information.

Your Personally Identifiable Information is transferred by Edcor to another country only if it is required or permitted under applicable data protection law and provided that there are appropriate safeguards in place to protect your Personally Identifiable Information. By using our Sites, you represent that you have read and understood the above and hereby consent to the storage and processing of Personally Identifiable Information that you provide directly to us on our Site.

The EU-US Privacy Shield enables data transfers to the United States in compliance with EU data protection requirements. In compliance with the US-EU Privacy Shield Principles, Edcor commits to resolve complaints about your privacy and our collection or use of your Personally Identifiable Information. Individuals in the EU with questions or concerns about the use of their Personally Identifiable Information please contact us as set forth in Section 14 below. Edcor remains liable under the Privacy Shield Principles if a third party service provider we use to process your Personally Identifiable Information processes such information in a manner inconsistent with the Privacy Shield Principles, except where Edcor is not responsible for the event giving rise to the damage.

If you have a question or concern that cannot be satisfied by contacting us, Edcor will refer unresolved privacy complaints under US-EU Privacy Shield to an independent dispute resolution mechanism operated by VeraSafe. Within the scope of this privacy notice, if a privacy complaint or dispute cannot be resolved through Edcor Data Services LLC’s internal processes, Edcor Data Services LLC has agreed to participate in the VeraSafe Privacy Shield Dispute Resolution Procedure. Subject to the terms of the VeraSafe Privacy Shield Dispute Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe under the Privacy Shield Dispute Resolution Procedure, please submit the required information to VeraSafe here: https://www.verasafe.com/privacy-services/dispute-resolution/submit-dispute/. If you are unsatisfied with the VeraSafe Privacy Shield program, individuals in the EU may seek redress from a binding arbitration mechanism, the Privacy Shield Panel. Edcor’s participation in the EU-U.S. Privacy Shield Framework is subject to investigation and enforcement by the Federal Trade Commission. If there is any conflict between the policies in this privacy policy and the Privacy Shield Privacy Principles, the Privacy Shield Privacy Principles shall govern. To learn more about the Privacy Shield program, please visit https://www.privacyshield.gov. To see the list of self-certified Privacy Shield companies, please visit https://www.privacyshield.gov/list.

You have the following rights under the GDPR:

Be informed about the collection and use of your personal data
Access your personal data
Correct errors in your personal data
Erase your personal data
Object to the processing of your personal data.
- This right is also available to individuals whose personal data is processed by us for direct marketing purposes. If you object to the processing of your personal data for direct marketing purposes, we shall stop processing within 30 days of receipt of your request.
Export your personal data
Restrict our processing of your personal data for specific reasons, including any of the purposes supported by the legitimate interest legal bases (see the section above).
Not to be subject to a decision based solely on automated decision making

A.2 For Individuals Based in California

This section provides additional specific information for consumers based in California as required by the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”) - which significantly amends and expands the CCPA.

A.2.1 Collection and Use of Personal Information

In the last 12 months, we have collected the following categories of personal information:

Identifiers, such as your name, mailing address, email address, zip code, telephone number or other similar identifiers
California Customer Records (Cal. Civ. Code § 1798.80(e)), such as username and password, company name, job title, business email address and department
Internet or network information, such as your browsing history, log and analytics data, information about the device(s) used to access the services and information regarding your interaction with our websites or services and other usage data
Geolocation data, such as information about your location (at country and city level) collected from your IP address
Sensory Information, the content, audio and video recordings of conference calls between you and us that we record where permitted by you and/or the law
Profession/employment information that you send to us when applying for a position included in your CV and cover letter
Other personal information, such as personal information you provide to us in relation to a survey, comment, question, request, article download or inquiry and any other information you upload to our application

We collect personal information directly from you, from your browser or device when you visit our websites, from third parties that you permit to share your information or from third parties that share public information about you, as stated above.

See the section above, “How We Use Personal Information,” to understand how we use the personal information collected from California consumers.

A.2.2 Recipients of Personal Information

We share personal information with third parties for business purposes. The categories of third parties to whom we disclose your personal information may include: (i) our service providers and advisors, (ii) marketing and strategic partners; (iii) ad networks and advertising partners; (iv) analytics providers; and (v) social networks.

Please see the “How We Share Information” section of the Privacy Policy above for more information on categories of information disclosed in the preceding 12 months as well as third parties information disclosed with.

A.2.3 California Privacy Rights

As a California resident, you may be able to exercise the following rights under the CCPA in relation to the personal information about you that we have collected (subject to certain limitations at law):

The right to access/know any or all of the following information relating to your personal information that we have collected and disclosed in the last 12 months (upon verification of your identity):
- The specific pieces of personal information we have collected about you
- The categories of personal information we have collected about you
- The categories of sources of the personal information
- The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed
- The categories of personal information we have sold and the categories of third parties to whom the information was sold, and
- The business or commercial purposes for collecting, selling or sharing the personal information.
The right to request deletion of personal information we have collected from you, subject to certain exceptions.
The right to opt-out of personal information sales to third parties now or in the future. However, we do not sell your personal information.
The right to opt-in to personal information sales to third parties for consumers under the age of 16. However, we do not sell personal information of minor consumers.

You also have the right to be free of discrimination for exercising these rights.

In addition to the rights mentioned above, the CPRA grants California residents with the following additional rights:

The right to opt-out of sharing of personal information to third parties now or in the future.
The right to request rectification/correction of inaccurate personal information, considering the nature and purposes of the processing of the information.
The right to limit use and disclosure of sensitive personal information to that which is necessary to perform the services or provide the goods reasonably expected by an average consumer

Please note that if exercising these rights limits our ability to process personal information (such as a deletion request), we may no longer be able to provide you with our products and services or engage with you in the same manner.

A.2.4 How to Exercise Your California Consumer Rights

To exercise any of your rights mentioned above, please submit a request by contacting us at www.Edcor.com click on Contact Us.

We will need to verify your identity before processing your request.

In order to verify your identity, we will generally require sufficient information from you so that we can match it to the information we maintain about you in our systems. Sometimes we may need additional personal information from you to be able to identify you. We will notify you.

We may decline a request to exercise the right to know and/or right to deletion under the CCPA as well as your right to rectification under the CPRA, particularly where we cannot verify your identity or locate your information in our systems or as permitted by law.

You may choose to designate an authorized agent to make a request under the CCPA or CPRA on your behalf. No information will be disclosed until the authorized agent’s authority has been reviewed and verified. Once an authorized agent has submitted a request, we may require additional information (i.e., written authorization from you) to confirm the authorized agent’s authority.

If you are an employee/former employee of a Edcor Data Services client that uses our application and services, please direct your requests and/or questions directly to your employer or former employer.

If you are a third party (auditor, business associate, etc.), who was given access to the Edcor Data Services application by a Edcor Data Services client, please direct your requests and/or questions directly to the Edcor Data Services client that gave you access.

Minors Under Age 16

Our application and services are intended for business use, and we do not expect them to be of any interest to minors. We do not intentionally collect any personal information of consumers below the age of 16. We do not sell the personal information of California consumers.