SmartLab Learning (Creative Learning Systems) is committed to protecting the privacy of visitors to our website, as well as our clients and customers. Any information given to Creative Learning Systems through this website will be used strictly by Creative Learning Systems. Volunteered information may be stored by us but will not be disclosed to any outside entity. We will not give, sell, rent or exchange the information with anyone else without your prior consent except as compelled by law (see the Compelled Disclosure section).
What Is Personal Data?
Personal data is any information relating to an identified or identifiable natural person. Standard website tracking via server logs and website analytics is not identifiable, and therefore not personal data. Information submitted via a contact form is, as name and email identify a person.
Which Data We Collect and Process
In general, Creative Learning Systems processes personal data that you as a user of the Products make available to us, for example by using our Products, and that others provide to us (“Data”).
Categories of Personal Data
These are the categories of personal data we collect directly or indirectly from you:
Identity information—includes: name (first, last), date of birth, e-mail address, gender, profile picture, job title, job description, unique consumer identifier number, social media identifiers and information passed along to us via your Facebook or Google account, and your device fingerprint. We use it to verify your identity.
Contact information—includes: your phone number, shipping and billing address, e-mail address, Messenger ID, social media handle, any other communication channel you have used to contact us for more information. We use it to contact you for different reasons depending on the purpose.
Location information—includes: your residential or business location, current log-in location (IP address), and/or GPS location (if you wish to share it with us, for example through your mobile device settings) or other phone related location data (e.g. via WiFi or Bluetooth), or the specific Creative Learning Systems site you visited that might give us clues about where you are. We use it to provide our services and adapt your experience to your location.
Purchase information—includes: payment provider, duration of your Creative Learning Systems subscription, and price. We use payment providers to process payments. Although we do not store any credit card information ourselves, we store a payment ID number that is given out by the respective provider (e.g. Apple, Google, PayPal) and can be allocated to you. We use it to process your payments.
Behavioral and Profile information—includes: your purchase history, your purchase preferences, company interactions, social media interactions with us, and any other intelligence we have about you to help us learn you as a consumer better, including “Community information.” We use it to know you better as a consumer, so we can send you marketing messages containing only products and services that we think you might be interested in.
Community information—includes: friendship and follower information in the Creative Learning Systems community, information provided by you when you participate in various Creative Learning Systems events and groups/communities either as a teacher, team member, a participant or as a promoter of our events, including for example: pictures, videos, your team, your interests and preferences, your feedback, leaderboards, event participation, joined groups and registration details.
If you explicitly allow us to access your phone book, we will compare the email addresses of your contacts with email addresses from registered users within the Creative Learning Systems community and send you a list with friend suggestions. We do not store this information in any way.
We use Community information to operate our products, to organize the events and communities, and to connect you with other members within our communities.
Social Media information—includes: information obtained through your interaction with us on various social media channels such as Facebook, Instagram, Google, etc., including: any social media information that is publicly available such as your social media handles, social media interactions and public postings, your “Likes” and other reactions, your social media connections, your photos that are public, or those you send to us by mentioning us or following our social media posts by using “handles” or “hashtags.” We obtain this information from the social media network (e.g. Facebook, Snapchat, Instagram, etc.) directly or indirectly through third-party agencies we have agreements with. We will receive information about your friends on Facebook if you explicitly allow us to access it.
Device information—includes: Information about your device or browser that give us an idea about your browsing behavior or device usage. Your device information is collected by our apps, and your browser information is collected by our cookies, tags, and pixels. This is often required for network security purposes. This includes, but not limited to: IP address, date and time of the visit, how long you remained on our website, transmitted data volume, the referral URL (if you came to our site via a different site or an advertisement), the pages visited on our site, your browser type (including language and version of the browser software) and add-ons, device identifier and features, device type, versions, operating system.
Preference information—includes: preferred language, login location, units (distance, weight, temperature), and your product reviews. We use it to give you convenience when you visit and/or shop on our sites and apps.
Data from Others—Registration via Facebook or Google. If you register a Creative Learning Systems account via social login, we will receive the following information:
- Facebook Inc. (1601 South California Avenue, Palo Alto, CA 94304, USA, “Facebook”): First and last name, email address, gender, birthdate, profile picture;
- Google Inc. (1600 Amphitheatre Parkway Mountain View, CA 94043, USA, “Google”): First and last name, email address, gender, birthdate; and profile picture.
Our servers may automatically record the numerical Internet Protocol (IP) address of the computer you are using; the browser software you use and your operating system; the date and time you access our site; and the Internet address of the website from which you linked directly to our site. We do not connect this information to your name or identity. We use this information to measure the number of visitors to different sections of the site, to diagnose and correct system errors, and to improve the site. We delete this information after three months.
A cookie is a tiny text file stored on your computer. Cookies store data that is used to help make sites work. Only we can access the cookies created by our website. You can control your cookies at the browser level. Choosing to disable cookies may hinder your use of certain functions. For more information about cookies, visit allaboutcookies.org.
Staff of Creative Learning Systems may have an online account that includes name and email to manage the website and update our contact database. These accounts are active as long as staff are with the company and deactivated upon leaving.
Embedded Content from Other Websites
We save your billing information and other information gathered about you for as long as needed for accounting purposes or other obligations deriving from law.
We do not intend to collect or knowingly collect information from individual children. All login credentials used by children rely on team logins.
What Rights You Have Over Your Data
If you have an account on this site you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
If we are required by law to disclose the information that you have submitted, we will attempt to provide you with notice (unless we are prohibited) that a request for your information has been made in order to give you an opportunity to object to the disclosure. We will attempt to provide this notice by email, if you have given us an email address, or by postal mail if you have entered a postal address. We will independently object to overly broad requests for access to information about visitors to our site. If you do not challenge the disclosure request, we may be legally required to turn over your information.
How We Protect Your Data
We do our best to keep your personal data safe. We use safe protocols for communication and transferring data (such as HTTPS). We use anonymizing and pseudonymizing where suitable. We monitor our systems for possible vulnerabilities and attacks. Even though we try our best we cannot guarantee the security of information. However, we promise to notify suitable authorities of data breaches. We will also notify you if there is a threat to your rights or interests. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.
Categories of Personal Information Collected. In the preceding 12 months, we have collected the categories of personal information listed below. For more details about the data points we collect, please see section “3. Which Data We COLLECT AND Process” above.
- Identifiers, such as name, email addresses, and billing and shipping address for online purchases, unique personal identifier, online identifier, Internet Protocol address, or other similar identifiers.
- Categories of personal information described in the California Customer Records statute (California Civil Code Section 1798.80), including payment information and, for employment candidates, education and employment history.
- Characteristics of protected classifications under California law, such as gender and age (over 40).
- Commercial information, including records of products or services purchased or purchasing habits.
- Internet and other similar network activity, such as browsing history or information regarding a consumer’s interaction with our website or products.
- Geolocation data.
- Audio and visual information, such as pictures you may upload to our site and recorded customer services calls.
- Professional or employment-related information, for example, from employment candidates.
Your Rights. Under the California Consumer Privacy Act of 2018 (“the CCPA”), California consumers have the right to request access to the specific pieces of personal information we have collected about them in the last 12 months. You may also request additional details about our information practices, including the categories of personal information we have collected about you, the categories of sources of such collection, the business or commercial purpose for collecting personal information, the categories of third parties with whom we share your personal information, the categories of personal information we have disclosed about you in the preceding 12 months. If you are a California consumer, you also have the right to request deletion of your personal information (subject to certain exceptions), to opt out of sales of personal information and to receive equal service and price and not be discriminated against even if you exercise any of their other CCPA rights.
Please note that any CCPA rights requests made before January 1, 2020 will be treated as if made on January 1, 2020.
California consumers may make a rights request by sending a request via email to the Email Address, via mail to our postal address or by making a call to our toll-free service number. For all relevant contact information please see Section “10. Questions, Complaints and Support” above. Your request must include sufficient information that allows us to reasonably verify you are the person about whom we collected personal information, which may include your email address, name and account id (which is required only if you already have an account with us). We will not discriminate against you if you choose to exercise your rights under the CCPA.
Sale of Personal Information. We do not sell any of your personal data to third parties.
Privacy and Compliance Manager
Creative Learning Systems
1801 Lefthand Circle
Longmont, CO 80501