Privacy

EVERYDAY SPEECH, LLC

PRIVACY POLICY

 

Last Updated: July 12, 2018

Your privacy is important to us.  This Privacy Policy sets forth Everyday Speech’s (“Everyday Speech”, “we”, “us”, or “our”) privacy practices in connection with Everyday Speech’s services and features (“Services”) available through our mobile application (the “App”) and through on Everyday Speech’s web-based social learning platform (together with the App, the “Platform”).  The Platform is located at https://www.everydayspeech.com/ and any related sub-domains (the “Website(s)”) and provided through such Website and through our App, as made available by Everyday Speech from time to time. This Privacy Policy applies only to information collected by Everyday Speech from users of our Services and visitors to our Platform or Website. This Privacy Policy does not apply to information collected by Everyday Speech in other ways, including offline.  Access to the Services is provided pursuant to the Terms of Service accessible on our Platform and Website.  Capitalized terms used but not defined in this Privacy Policy, shall have the meaning set forth in the Terms of Service.

Summary

Because Everyday Speech involves provision of information regarding you and your Students, we take precautions to ensure that you and your Students’ personal information is protected.

Rather than a dense legalistic Privacy Policy we have tried to write a clear, open and transparent Privacy Policy that an average human can understand without retaining a lawyer.  Here are a few highlights about the personal information we collect through our Services, how we use it, and your choices about its use:

  • We won’t sell your data.
  • We won’t spam your email or social networks.
  • We’ll be open and transparent as to how we will use your information within Everyday Speech.

Information About You

We use your Personal Information to communicate with you, provide you with our Services, and to help us improve our Services.  We collect your name and contact information, and if you subscribe to or purchase fee-bearing Services, we also collect your payment information through third party online payment services.

We use cookies and other technologies to keep track of your use of our Services and to provide a personalized experience. Cookies are described and discussed below. We also use cookies to help us measure usage and improve the quality of our Services.

By using our Services, you indicate your consent for Everyday Speech to send cookies to your computer or other device in order to uniquely identify your browser and improve the quality of our Services. You may turn off cookies in your browser however, in doing so, some or all of our Services may not work.

 

 Your Privacy Choices

  • You may review and correct your Personal Information and preferences.
  • You may opt-out of marketing and promotional emails from us.
  • You may opt-out of phone and postal marketing.

Important Information

We will update the “last updated” date to indicate the effective date of any changes to our Privacy Policy.

How to Reach Us if You Have a Question

By email to [email protected]

Protecting Your Data and Ensuring Your Privacy at Everyday Speech

The Everyday Speech Services

What is Personal Information?

What information do we collect and when do we collect it?

How do we use the Information we collect?

What does Everyday Speech do with your Content?
What information do we share with third parties?

User Communications

Links to Other Services

What steps do we take to protect your Information Online?

What choices do you have regarding the use of your information?

Your Rights: Reviewing, Changing or Deleting Your Information

Retention of Your Information

Minors

Information for European or Swiss Union Users

Dispute Resolution

International Transfer

Lawful Bases for Processing

Information for California Residents

Changes to our Privacy Policy

Questions?

 

 

The Everyday Speech Services

Everyday Speech enables you to provide social skills training and related content to students (“Students”) by providing you with features and functionality to enable you to provide selected content to such Students through the Platform.

What Is Personal Information?

“Personal Information” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as  a name, address, telephone number, mobile number or e-mail address, an identification number, location information, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.  “Sensitive Personal Information” means racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union members, the processing of genetic, biometric data for purposes of uniquely identifying a natural person, and information concerning an individual’s health, sex life, or sexual orientation.  We treat your Personal and Sensitive Personal Information as confidential.

“Other Information” is any information that is not Personal Information or Sensitive Personal Information.  Personal Information does not include anonymized or “aggregate” information, or publicly available information that has not been combined with Personal Information or Sensitive Personal Information.

What Information Do We Collect And When Do We Collect It?

We may collect your Personal Information in the following circumstances:

  • When you voluntarily provide it to us, such as when you register for an account by creating a username and password (“Everyday Speech Login Credentials”), send us an email or post information or other content to our Site or Service.
  • When you choose to sign into or create an Everyday Speech account.
  • If you apply for or purchase a Service requiring billing or payment information on our Platform, we require that you provide certain additional Personal Information, including your address, phone number, and credit card number (“Payment Information”).  This information is necessary to process your requests and to contact you.

When you utilize the Services, we also receive certain Other Information about you or your use of the Services.  Such Other Information may be collected using various technologies, including:

  • Logs: We track the data you see in Everyday Speech and how you interact with it by automatically collecting certain information such as, the pages you visit or features you use within the Services, the date and time of your activities on the Services, the URLs from the websites you visit before and after navigating to the Services, your software and hardware attributes (including operating system type and version, App version, device type, and device identifiers, including IDFA and/or Advertising IDs), your browser type and version, your interaction with our Platform, and your general geographic location derived through your IP address (e.g., your city, state, or metropolitan region). To obtain such information, we may use web logs or applications that monitor use of our Platform and/or recognize your device and gather information about its online activity. We treat this information as private data if we combine it with or link it to any of your Personal Information. Otherwise, it is used in aggregate form only. We use tracking data about users in an aggregated form to inform us about how Everyday Speech is being used to help us provide a better user experience.

 

  • Cookies: Like almost all websites today, Everyday Speech uses cookies to determine whether you are logged in on your computer and to recognize repeat visitors. We send cookies to your computer in order to uniquely identify your browser and improve the quality of our Services. Cookies are small pieces of information that a website sends to your computer’s hard drive while you are viewing a site. We may use both session cookies (which expire once you close your browser) and persistent cookies (which stay on your computer until you delete them).  If you wish to restrict or block the cookies which are set by Everyday Speech, or by any other website, you can do this through your browser settings. Please note, if you choose to disable cookies, some of our Services may not work properly or at all.

 

  • Web beacons: The Services or the emails that you receive from us may use an application known as a “web beacon” (also known as a “clear gif” or “pixel tag”). A web beacon is an electronic file that usually consists of a single-pixel image. It can be embedded in a web page or in an email to transmit information. For example, it allows an email sender to determine whether a user has opened a particular email.

 

  • Local storage: We may collect and store information (including Personal Information) locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches.

Everyday Speech keeps Personal Information contained in your cookies and obtained through the other tracking technologies confidential.  We do not set any cookies outside of the everydayspeech.com domain.

We also may partner with certain third parties to collect, analyze, and use some of the Personal and Other information described in this section.  For example, we may allow third parties to set cookies or use web beacons on the Services or in email communications from Everyday Speech or we may use third party services to monitor use of our Platform.  This information may be used for a variety of purposes, including analytics and online behavioral advertising.

How Do We Use the Information We Collect?

We use your Personal Information and Other Information collected through our Services for the following purposes:

  • to provide our Services or information you request, and to process and complete any transactions;
  • to respond to your emails, submissions, questions, comments, requests, and complaints and provide customer service;
  • to monitor and analyze usage of the Services and trends, and to personalize and improve our Services and our users’ experiences on our Services, such as content, or features that match their profiles or interests, and to increase the functionality and user friendliness of our Services;
  • to send you confirmations, updates, security alerts, and support and administrative messages and otherwise facilitate your use of, and our administration and operation of, our Services;
  • to contact you about the Services in which you have expressed interest or that might be of interest to you; and
  • for any other purpose for which the information was collected.

What does Everyday Speech do with your Content?

As with your Personal Information, we will treat your Content as confidential private data except for the uses and disclosures described in this Privacy Policy. Your Content is stored securely on our servers and will remain private to you, within your Everyday Speech account, unless you choose to share such information with any other user.

What Information Do We Share with Third Parties?

Everyday Speech exists to make your professional network more actionable, not to sell your data.  However, we share personal information as follows:

Service Providers, Agents and Related Third Parties: We sometimes hire other companies to help us provide the Services to you.  Examples include third-party payment processors, companies who send emails on our behalf, and providers who are working with us in connection with the operation of our Services. Such service providers are only provided with the information they need to perform their specific function, will only use your Personal Information to perform the services requested by us, and we make efforts to ensure they are subject to confidentiality restrictions consistent with this Privacy Policy.

Requests to other Everyday Speech users (and non-users): Some communications you initiate through Everyday Speech (e.g., an invitation sent to a non-user or a task you assign to another Everyday Speech user) will list your primary email address and name in the header of the message.

 

Facebook Custom Audiences and Similar Programs:  We may partner with Facebook and other social media partners to deliver advertisements to our users via the Facebook Custom Audiences program or similar third-party programs.  In order to identify and reach our users on Facebook or another third-party service, we may share information such as an email address or phone number with Facebook or another third-party service.  For more information about custom audience targeting and how to adjust your social media advertising preferences, please review the privacy policy of your social media provider.

With Your Consent: We may share your Personal Information when you give us your consent to do so, including if we notify you on our Services that the information you provide will be shared in a particular manner and you provide such information.

Legal Processes: We may also disclose your Personal Information if required to do so by law or when we believe in good faith that we are lawfully authorized or required to do so or that doing so is reasonably necessary or appropriate to comply with the law or legal processes or respond to lawful requests or legal authorities, including responding to lawful subpoenas, warrants or court orders; when we believe that disclosure is necessary to protect our rights or the rights, property or safety of others; to enforce or apply our Privacy Policy, our Terms of Service or our other policies or agreements.

Transfers: We might sell or buy business assets.  We may share your Personal Information in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition, or in any other situation where Personal Information may be disclosed or transferred as one of the business assets of us.

Analytics: We partner with certain third parties to collect the Other Information discussed above and to engage in analysis, auditing, research, and reporting. These third parties may use web logs or web beacons, and they may set and access cookies or use similar tracking technologies on your computer or other device. In particular, our Services use Google Analytics and Mixpanel. You may opt out of the use of cookies by Google Analytics here, and Mixpanel here.

Online Interest-Based Advertising: The Services also enable third-party tracking mechanisms to collect your Other Information for use in online interest-based advertising. For example, third parties may use the fact that you visited our website or used our mobile app to target online ads to you. In addition, our third-party advertising networks might use information about your use of our website or app to help target advertisements based on your online activity in general. For information about interest-based advertising practices, including privacy and confidentiality, visit the Network Advertising Initiative website or the Digital Advertising Alliance website.

The use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies, and not this privacy policy. If you prefer to prevent third parties from setting and accessing cookies on your computer or other device, you may set your browser to block cookies. Additionally, you may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out here, or of companies participating in the Digital Advertising Alliance by opting out here.  If you are an individual of the EU or Switzerland, you may opt-out here.  Although our Services currently do not respond to “do not track” browser headers, you can limit tracking through these third-party programs and by taking the other steps discussed above.

Please note that the opt-out will apply only to the specific browser or device from which you opt out, and therefore you will need to opt out separately on all of your browsers and devices.  If you delete or reset your cookies or mobile identifiers, change browsers, or use a different device, any opt-out cookie or tool may no longer work and you will have to opt out again.

Aggregated information: We may share aggregated demographic information about our user base with our partners. Such aggregated information does not identify individual users.  We do not link this aggregate user data with personal information.  Our Privacy Policy does not restrict or limit our collection and use of aggregate user data.

User Communications

You may choose to provide us with another person’s e-mail address so that person may be invited to create an account on our Service. By providing us with another person’s e-mail address, you represent to us that you have obtained the consent of the person concerned as regards such disclosure to us of that e-mail address.  We may disclose such information if required to do so in order to comply with legal process, as described above.

Links to Other Sites

Our Services may contain links to other sites.  Any Personal Information you provide on the linked pages is provided directly to that third party and is subject to that third party’s privacy policy. Our Privacy Policy does not apply to such linked sites, and we are not responsible for the content or privacy and security practices and policies of these sites or any other sites that are linked to from our Services.

What Steps Do We Take To Protect Your Information Online?

We use reasonable physical, technical, and administrative security measures to protect your Personal Information in an effort to prevent loss, misuse and unauthorized access, disclosure, alteration and destruction. Please be aware, however, that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse.

What Choices Do You Have Regarding the Use of Your Information?

You may withdraw your consent to process your Personal Information at any time.  If you do so, you will be unable to use the Services.

You may “opt out” of receiving marketing or promotional communications from us by following the instructions in those communications or by emailing us at [email protected] If you opt out, we may still send you non-promotional emails, such as emails about your Everyday Speech account or our ongoing business relations.

Your Rights: Reviewing, Changing or Deleting Your Information

You may review, update, correct or delete the Personal Information in your account from within the Service itself or by contacting us at [email protected]  By deleting your data in your account, we may deactivate your account. You may request deletion of your data at any time.  Your account will be closed after a period of inactivity of six months or such other period of time as we may choose from time to time.  You also authorize us, on your behalf, and in accordance with your account preferences to delete information when not reasonably needed for the Services.  If you have shared your Content with others and they have not deleted it, or it was copied or stored by other users, Everyday Speech will not be obligated to delete such information.

If you are an EU or Swiss individual, you have the right to object to processing and to data portability, in some circumstances, as well as the right to lodge a complaint with a supervisory authority.

Retention of Your Information

We retain information for as long as reasonably necessary to deliver our Services to you or to fulfill the purposes described in this Policy.  You may delete the Personal Information in your account as described above.  Please note that, in limited circumstances, we may retain information for a longer period of time as required by law.

Minors

We do not collect, and you agree not to provide to us, information regarding Students or minors.

Information for European Union and Swiss Users

Everyday Speech complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of Personal Information transferred from European Union and Switzerland to the United States, respectively. Everyday Speech has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  You can learn more about the Privacy Shield program here, and to view our certification page, please visit here.

Everyday Speech is responsible for the processing of Personal Information it receives under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf.  Everyday Speech complies with the Privacy Shield Principles for all onward transfers of Personal Information from the EU and Switzerland including the onward transfer liability provisions.

With respect to the Personal Information received or transferred pursuant to the Privacy Shield Framework, Everyday Speech is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.  In certain situations, Everyday Speech may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Dispute Resolution

In compliance with the EU-US and Swiss-US Privacy Shield Principles, Everyday Speech commits to resolve complaints about your privacy and our collection or use of your Personal Information. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact Everyday Speech at [email protected]

Everyday Speech has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.

Under certain conditions more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

International Transfer

The Services are operated from and hosted on servers located in the United States.  Your information may be transferred around the world to countries in which we do business, including to affiliates, service providers or third parties, which may be located in jurisdictions that may not have the same level of data protection laws as those in your home country.  By using the Services or by providing any personal information to us, you expressly consent to such transfer and processing.

Lawful Bases for Processing

We will only collect and process Personal Information about you where we have lawful bases.  Our lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you, such as when you purchase a Premium Service) and our legitimate interests (such as to comply with applicable laws and enable or administer our business).

Information for California Residents

If you are a California resident under 18 years of age and a registered user of our Services, you may request that we remove content and information that you publicly post on our Services.  To obtain removal of such content and information, please send us an email at [email protected] with a short description of the content or information you would like to have removed.  Please note that such a request does not necessarily ensure complete or comprehensive removal of content posted by you, since the content and information may remain in our databases, may remain visible in a manner that does not identify you, or may have been re-posted by another user.

Changes to our Privacy Policy

Everyday Speech may update this Privacy Policy from time to time.  If we decide to change our Privacy Policy, we will post those changes on this page with an “effective date” indicating when the changes will take effect.  We encourage you to review this Privacy Policy periodically. If you have questions or concerns regarding our Privacy Policy, please contact us at: [email protected]

Questions?

Please contact us at [email protected] if you have any questions about our Privacy Policy.

 

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