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Terms & Policies

<ĢƵ>ĢƵl respects the privacy of visitors to its website.

To protect online privacy, we have implemented the following terms and policies.

 

Terms & Conditions

Last Updated: May 17, 2024

These Terms & Conditions (“Terms”), including our PRIVACY POLICY (incorporated herein by this reference) govern your access or use of the websites and online platform (collectively “Platform”) of ĢƵl, a Minnesota nonprofit corporation, and its affiliated brands, including Redleaf Press and ĢƵl Institute (“Company”, “we”, “us”, and “our”) to access any information, educational materials and other content (collectively “Content”) and/or to acquire our books, guides, courses or other materials sold through the Platform (collectively “Product(s)”).

By using the Platform and/or purchasing our Product(s), you signify your assent to these Terms. Notwithstanding the foregoing, if you acquire our Product(s) through an organization or company that is under a separate agreement with us, such agreement will supersede these Terms. If you do not agree to all of these Terms, do not use the Platform or purchase the Product(s). We may modify these Terms from time to time, and such modifications shall be effective immediately upon posting of the modified Terms. Your continued use of the Platform and subsequent purchases of Product(s) means you have accepted and are subject to these modified Terms. Your use of the Platform, the Content, or the Product(s) purchased through the Platform are subject to these Terms, in addition to our PRIVACY POLICY.

THE PLATFORM AND THE CONTENT PROVIDED THROUGH THE PLATFORM AND THE PRODUCT(S) SOLD THROUGH THE PLATFORM ARE FOR YOUR PERSONAL INFORMATIONAL PURPOSES ONLY AND ARE NOT INTENDED TO PROVIDE PROFESSIONAL OR LEGAL GUIDANCE OR ADVICE. WE MAKE NO REPRESENTATIONS AND CANNOT CONFIRM WHETHER THE PLATFORM, PRODUCT(S), OR CONTENT ARE COMPLIANT WITH APPLICABLE LAWS OR GOVERNMENT REGULATIONS IN YOUR AREA OF PRACTICE OR GEOGRAPHIC LOCATION. PLEASE CONTACT A PROFESSIONAL ADVISOR IF YOU HAVE ANY QUESTIONS ABOUT LAWS OR GOVERNMENT REGULATIONS THAT MAY APPLY TO YOU.

WE DO NOT GUARANTEE THE RESULTS OF ANY CONTENT OR PRODUCT(S) PROVIDED THROUGH THE PLATFORM.

NEITHER WE NOR ANY OF OUR DIRECTORS, OFFICERS, EMPLOYEES, OR AGENTS PROVIDE ANY ADVICE AS TO THE APPROPRIATENESS OR ADVISABILITY OF THE CONTENT PROVIDED THROUGH THE PLATFORM OR THE PRODUCT(S) SOLD THROUGH THE PLATFORM. IF YOU ARE CONCERNED WITH THE USE OF OR DISSATISFIED WITH THE CONTENT OR PRODUCT(S), PLEASE IMMEDIATELY DISCONTINUE USE OF THE CONTENT AND/OR PRODUCT(S) AND CONTACT US AT SUPPORT@THINKSMALLINSTITUTE.ORG.

Your Rights and Obligations

Services Description.  We provide you with our Product(s) either in a direct to individual basis, in which case your rights and obligations are specified in these Terms and our Privacy Policy. You may also receive access to our Product(s) through an organization, in which case we may enter into a service agreement with the organization desiring to obtain our Product(s) for the organization’s employees, agents, or other third parties as the organization determines. If our Product(s) are provided to you pursuant to a services agreement, the fees for our Product(s) and other terms of our Product(s) will be as specified in such services agreement and those terms will supersede any conflicting provisions of these Terms.

User Account.  You may be required to create a user account to purchase Product(s) through our Platform. If you are under the age of 18, we require that you inform your parent or guardian and have their consent to create a user account.

Passwords/Security.  You shall be solely responsible for the security, confidentiality and integrity of all messages and the information that you receive, transmit or store via the Platform and/or your user account. If you elect to set up a user account on the Platform, you are responsible for taking all reasonable steps to ensure that no unauthorized person shall have access to your account or password and you shall not share your user account credentials with any unauthorized users. You agree to bear all responsibility for the confidentiality of your password and all use or charges incurred from use of the Platform with your password. You shall not engage in any misrepresentation, including impersonation, with respect to your role, responsibilities, or identity when creating a user account and accessing our Platform and Content or purchasing our Product(s).

Privacy.  We will protect the privacy of information provided in your user account in accordance with our PRIVACY POLICY.

Charges.  Our Product(s) may or may not include the fees for which you are responsible, depending on how you acquired our Product(s) (i.e. direct or through an organization). You are responsible for paying the purchase price, and any tax for the Product(s) you purchase as noted on the Platform’s shopping cart or final sales page. Payments may be made in the currencies and via the payment methods specified on the Platform’s shopping cart of final sales page.

Taxes & Duties.  Prices displayed on the Platform are exclusive of taxes. When you proceed to purchase Product(s), any sales, use or value added tax (where applicable) will be calculated on the total Product(s) value when possible. Please note that all taxes and duties for the Product(s) purchased are your responsibility. We are not responsible for paying sales or use taxes on your purchases through the Platform.

Payments.  We only accept payments for Product(s) via our third party payment processing provider and you must confirm your identity before any payment is accepted. You understand and acknowledge that while we do not collect, retain, or process payment in any way, we do collect limited information from the third party payment processor to confirm the payment has been made. You further authorize our third party payment processor to charge your preferred payment method for amounts you owe when they are due. You must keep all payment information you provide up-to-date, accurate and complete. Any payments made by you are subject to the terms and conditions of our third party payment processor, currently Stripe, as posted on Stripe’s website and you agree to be bound by the same, as it may be modified from time to time. You acknowledge that we are not a party to any such terms and conditions posted on Stripe’s website. We reserve the right to cancel your ability to make payments in our sole and absolute discretion.

Access Limitations.  You shall be solely responsible for providing, maintaining, and ensuring compatibility with the Platform access requirements, all hardware, software, electrical or other physical requirements for your use of the Platform, including without limitation, mobile devices, telecommunications and Internet service provider access, connections, links, web browsers or other equipment, programs, and services required to access the Internet or the Platform. You acknowledge and agree that from time to time the Platform may be inaccessible or inoperable for any reason, including without limitation: (i) equipment malfunctions; (ii) periodic maintenance procedures or repairs; or (iii) other causes beyond our control. Additionally, because the Platform is accessed via the Internet or a mobile carrier, you may have connection issues due solely to your own Internet or telecommunications Platform provider or other technological access requirements. We are not responsible for any third-party access requirements (e.g. your ISP).

Third Party ĢƵ.  You acknowledge we contract with third party suppliers, licensors, developers, application and data hosting providers, wireless network services, payment processers, and other technology service providers to provide the Platform’s functionality (“Third Party ĢƵ“). We are responsible for ensuring that the Third-Party ĢƵ abide by these Terms. We are solely responsible for monitoring and supervising all necessary work of the Third-Party ĢƵ.

Our Right to Refuse.  You acknowledge that we are the owner of the Content and Product(s). Content is provided and Product(s) are sold on an “AS IS” and “AS AVAILABLE” basis. We reserve the right to not sell Product(s) to you if you request delivery to a country that is at war, or subject to another Force Majeure event, or that is currently under sanctions by the United Nations, or sanctions or an embargo by the United States.

Restrictions.  You acknowledge and agree that your use of our Content or access and use of our Platform is subject to our Acceptable Use Policy incorporated herein by this reference. Except as otherwise permitted under these Terms, you shall not (and shall not assist any third party to): (a) decompile, disassemble, or otherwise reverse engineer or attempt to reconstruct or derive any source code (or underlying ideas, algorithms, structure or organization) from the Platform, or from any other information by any means whatsoever; (b) distribute, disclose, or allow use of any of the software in any format through any timesharing device, service bureau, network, or by any other means, to or by any third party; or (c) modify or create a derivative work of the Platform, Content, or the information or any portion thereof. As a visitor to the Platform, you are prohibited from posting or transmitting any threatening, obscene, libelous, unlawful, or otherwise offensive material. You may not use your user account to send any unsolicited communication (e.g., spam). You are not permitted to link the Platform to any other website or off-site web pages without our prior written permission.

Submission of Information.  Any information, material, or idea you submit on the Platform will be considered non-confidential and non-proprietary except to the extent set forth in our PRIVACY POLICY. If any other information you submit constitutes personal data, you agree that we and our affiliates may transmit such personal data, including if necessary across international boundaries, as required to provide our Product(s) or the Platform and Content in according with our PRIVACY POLICY.

Disclaimers; Ownership, Limitations On Liability

No Warranty.  The Content and Product(s) provided through the Platform are believed to be accurate, but neither we nor our Third Party ĢƵ warrant or guarantee such accuracy. THE CONTENT AND THE PRODUCT(S), INCLUDING WITHOUT LIMITATION ALL PRICES AND SPECIFICATIONS FOR PRODUCT(S), PROVIDED THROUGH THE PLATFORM ARE SUBJECT TO CHANGE WITHOUT NOTICE. THE PLATFORM, PRODUCT(S), AND CONTENT ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS AT YOUR OWN RISK.

YOU ACKNOWLEDGE AND AGREE THAT WE HAVE NO OBLIGATION FOR ANY ERRORS (E.G. TYPOGRAPHICAL ERRORS) OR ANY WARRANTY, EXPRESS OR IMPLIED OF ANY KIND WHATSOEVER (INCLUDING WITHOUT LIMITATION, WARRANTIES OF TITLE OR NON-INFRINGEMENT, THAT THE PRODUCT(S), CONTENT OR PLATFORM ARE ERROR-FREEOR, OR ANY WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE) WITH REGARD TO THE PRODUCT(S) SOLD, THE CONTENT PROVIDED OR FOR THE PLATFORM.

Some jurisdictions do not allow the exclusion of implied warranties, so this exclusion may not apply to you.

Ownership, IP.  All Content provided through the Platform are protected by copyright owned or licensed by us and our logo and all other logos used on the Platform are protected by trademarks or service marks owned or licensed by us or our licensors. These copyrights, trademarks, and service marks may not be used without our prior explicit written permission. Content includes any and all types of information such as the “look and feel” of the Platform, data files, graphics, text, photographs, drawings, logos, images, sounds, music, video or audio files on the Platform. We try to ensure that the Content on the Platform is accurate and complete. You shall have no rights or interests therein except as set forth in these Terms. You acknowledge and agree that the Product(s) are sold by us and that we are solely liable and responsible for the Product(s) sold and information provided through the Platform. You agree that you shall not remove, obscure, or alter any proprietary rights notices (including copyright and trademark notices) which may be affixed to or contained within the Product(s), the Platform or the Content provided therein. The Product(s) are owned by us or our relevant Third Party ĢƵ and are provided in conformance to our obligations under the license terms with such Third Party ĢƵ.

Limitations On Liability For Third Party ĢƵ. YOU EXPRESSLY UNDERSTAND AND AGREE THAT YOU HAVE NO CONTRACTUAL RELATIONSHIP WITH ANY OF OUR THIRD PARTY PROVIDERS, AND THAT YOU ARE NOT A THIRD PARTY BENEFICIARY OF ANY AGREEMENT BETWEEN US AND ANY THIRD PARTY PROVIDER. IN ADDITION, YOU ACKNOWLEDGE THAT ALL SUCH THIRD PARTY PROVIDERS SHALL HAVE NO LEGAL, EQUITABLE, OR OTHER LIABILITY OF ANY KIND TO ANY USER, AND YOU HEREBY WAIVE AND DISCLAIM ANY AND ALL CLAIMS OR DEMANDS OF SUCH NATURE. YOU ACKNOWLEDGE AND AGREE THAT ANY THIRD PARTY PROVIDERS HAVE NO OBLIGATION FOR ANY WARRANTY, EXPRESS OR IMPLIED OF ANY KIND WHATSOEVER (INCLUDING WITHOUT LIMITATION, WARRANTIES OF TITLE OR NON-INFRINGEMENT, OR ANY WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE) WITH REGARD TO THE PRODUCT(S) AND/OR CONTENT PROVIDED THROUGH THE PLATFORM. YOU FURTHER ACKNOWLEDGE AND AGREE THAT WHILE SUCH THIRD PARTY PROVIDERS MAY AGREE TO REFUND THE FEES PAID FOR THE PRODUCT(S), SUCH THIRD PARTY PROVIDERS, TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, SHALL HAVE NO OTHER WARRANTY OBLIGATION WHATSOEVER WITH RESPECT TO THE PRODUCT(S) AND/OR CONTENT PROVIDED, AND ANY OTHER CLAIMS, LOSSES, LIABILITIES, DAMAGES, COSTS OR EXPENSES ATTRIBUTABLE TO ANY FAILURE TO CONFORM TO ANY WARRANTY WILL BE SOLELY AS PERMITTED UNDER THESE TERMS.

Damage Limitation. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL WE OR OUR THIRD PARTY PROVIDERS BE LIABLE FOR ANY INDIRECT, SPECIAL, PUNITIVE, INCIDENTAL, EXEMPLARY, OR CONSEQUENTIAL DAMAGES, OR ANY DAMAGES WHATSOEVER, RESULTING FROM ANY LOSS OF USE, LITIGATION, OR ANY OTHER PECUNIARY LOSS, INCLUDING LOSS OF GOODWILL OR REPUTATION, WHETHER BASED ON BREACH OF CONTRACT, TORT (INCLUDING NEGLIGENCE), PRODUCT LIABILITY, OR OTHERWISE, ARISING OUT OF OR IN ANY WAY CONNECTED WITH THE USE OR PERFORMANCE OF THE PLATFORM, CONTENT, OR PRODUCT(S), WITH THE DELAY OR INABILITY TO USE THE PLATFORM, OR WITH THE PROVISION OF OR FAILURE TO MAKE AVAILABLE ANY PRODUCT(S) OR CONTENT PROVIDED THROUGH THE PLATFORM, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. COMPANY SHALL BE LIABLE ONLY TO THE EXTENT OF VERIFIABLE, ACTUAL DAMAGES INCURRED BY YOU DIRECTLY RELATED TO THE PAID FOR PRODUCT(S) AND NOT TO EXCEED THE PURCHASE PRICE YOU PAID. YOU ACKNOWLEDGE AND AGREE THAT NEITHER WE NOR THIRD PARTY PROVIDERS ARE LIABLE FOR ANY PERSONAL INJURY, INCLUDING DEATH, CAUSED BY YOUR USE OR MISUSE OF THE PLATFORM, CONTENT, OR PRODUCT(S). Any claims arising in connection with your use of the Platform, any Content, or the Product(s), must be brought within one (1) year of the date of purchase. Remedies under these Terms are exclusive and are limited to those expressly provided for in these Terms. If you are dissatisfied with the Platform or the Product(s), your sole and exclusive remedy shall be the limited refund right or for you to discontinue use of the Platform or the Product(s).

Bargained For Basis.  YOU ACKNOWLEDGE AND AGREE THAT THE LIMITATIONS OF LIABILTY SET FORTH ABOVE ARE FUNDAMENTAL ELEMENTS OF THESE TERMS AND NEITHER THE PLATFORM, THE CONTENT, NOR THE PRODUCT(S), WOULD BE PROVIDED TO YOU ASBENT SUCH LIMITATIONS OF LIABILITY.

Links.  While this Platform may contain links to third party websites, we are not responsible for the content of any linked websites. If provided, we provide these links as convenience and we do not endorse the companies or contents of any linked websites.

Miscellaneous Provisions

Your Responsibility.  You understand that you are solely responsible for (and that we have no responsibility to you or to any third party for) any breach of your obligations under these Terms and for the consequences (including any loss or damage which we may suffer) of any such breach.

Compliance with Law.  You agree that you will not use the Platform for activities prohibited by any applicable state, federal, or other country’s laws, rules or regulations. You represent and warrant that: (i) you are not located in a country that is subject to U.S. Government embargo, or that has been designated by the U.S. Government as a “terrorist supporting” country; and (ii) you are not listed on any U.S. Government list of prohibited or restricted parties. We make no claims regarding our Platform, Content or Product(s) outside of the United States. If you access the Platform from outside the United States, you do so at your own risk and you are responsible for compliance with the laws of such jurisdiction.

Agreement.  These Terms constitute the entire agreement and understanding between you and us with respect to the subject matter hereof and supersede all prior and contemporaneous agreements, understandings, inducements, and conditions expressed or implied, oral or written, of any nature whatsoever with respect to the subject matter hereof. These Terms shall be binding upon and inure to the benefit of the parties, their successors, and assigns. These Terms and your user account may not be assigned without our express, prior written consent which may be withheld at our sole discretion. Notices under these Terms shall be in writing and shall be deemed given when: (i) delivered personally or by respected international carrier; (ii) three (3) business days after the date sent by certified mail, postage prepaid with return receipt requested; or (iii) delivered by email to support@thinksmallinstitute.org.

Governing Law.

  • These Terms and the resolution of any dispute related to the terms of these Terms or the Platform shall be governed by and construed in accordance with the laws of the State of Minnesota, without giving effect to any principles of conflicts of law.
  • The United Nations Convention on Contracts for the International Sale of Goods (CISG) shall not apply to these Terms.

Arbitration; Collection; Venue. Any controversy or claim arising out of or relating to these Terms will be settled by arbitration in Hennepin County, Minnesota, at a time and location designated by the arbitrator. Arbitration will be conducted by the American Arbitration Association in accordance with its Rules of Commercial Arbitration, and judgment upon the award rendered by a single arbitrator may be entered in any court having jurisdiction thereof. The arbitrator will be selected from a panel of persons having experience with and knowledge of the education industry and technology services. Nothing herein contained will bar either party from seeking equitable remedies or any claims related to intellectual property infringement in a court of appropriate jurisdiction sitting in Hennepin County, Minnesota. If we successfully enforce our rights under these Terms in the arbitration or court action we may be awarded our costs and expenses of the arbitration or other action, including reasonable attorney’s fees and costs.

Force Majeure.  Neither party shall be liable for any failure to perform its obligations hereunder, where such failure results from any act of God or other cause beyond such party’s reasonable control, excluding labor disputes, provided such party immediately notifies the other party.

No Waiver; Severability.  Any failure on the part of a party to these Terms to insist upon strict enforcement of any provision(s) of these Terms shall not be construed as a waiver of any provision or right. Should any provision of these Terms be held invalid or unenforceable, such invalidity will not invalidate the whole of these Terms, but rather that invalid provision will be amended to achieve as nearly as possible the same economic effect as the original provision and the remainder of these Terms will remain in full force and effect.

Third Party Beneficiary.  You acknowledge and agree that the Third Party ĢƵ (e.g., Apple, and Apple’s subsidiaries) are third party beneficiaries of these Terms, and that upon your acceptance of the terms and conditions in these Terms, such Third Party ĢƵ will have the right (and will be deemed to have accepted the right) to enforce these Terms against you as a third party beneficiary hereof.

Copyright © 2021-2024 ĢƵl. All rights reserved.

Privacy Policy

Last updated: May 17, 2024

This Privacy Policy governs the privacy practices for ĢƵl, a Minnesota nonprofit corporation and its affiliated brands, including Redleaf Press and ĢƵl Institute (“we,” “our,” or “us”). This Privacy Policy applies to information you provide to us when you create your user account, access our Content (defined below), or purchase our Products (defined below) by accessing our website and/or our online platform (collectively our “Platform”). This Privacy Policy specifies:

  • What personal information do we collect about you through our Platform?
  • How is this information used and with whom it may be shared?
  • What choices are available to you regarding the use of your data?
  • What are our security practices to protect the misuse of your information?
  • How can you correct any inaccuracies in the information?

Information We Provide and Collect

We are the owners of the information, educational materials, and other content (collectively “Content”) we provide through our Platform. This Privacy Policy specifies our rights to the information provided by you and/or collected through our Platform. Your information includes the information you provide in setting up your user account when you purchase our books, guides, courses or other materials (collectively our “Products”). We only have access to and/or collect information that you voluntarily provide us via our Platform, any email you send us, your user account, or other direct contact from you. We do not require you to set up a user account to access our website; however, an account is necessary to access our online platform and acquire our Products. For purposes of this Privacy Policy, “Personal Information” includes all personally identifiable information that is specific to you (e.g. name, address, phone number, email address, etc.). Except as specifically noted herein, we do not provide any Personal Information to any unaffiliated third party.

We may collect information about you through your use of our Platform with software application tools and data files (such as cookies and web log files), IP addresses, device state information, unique device identifiers, device hardware and OS information (“Usage Information”). You may be able to control such Usage Information through the control settings on your device or browser; but removing such Usage Information tools may impact the convenience to use or the functionality of the Platform.

We may collect and process information through our Platform about the location of your device using GPS or other location technologies, such as sensor data from your mobile device providing information about nearby Wi-Fi access points and cellular network towers (“Location Information”). We use Location Information solely as necessary to analyze and improve our Platform, Content, and Products.

Use and Disclosure of Your Information

We use your Personal Information as necessary to maintain your user account for the purpose of performing our services, and to provide our Products, Content, and Platform. In addition, we may use Personal Information, Usage Information, or Location Information we collect or you provide to us, in order to:

  • Respond to any questions you ask or to respond to the reason you contacted us. We do not share your Personal Information with any unaffiliated third party, unless necessary to respond to your request.
  • Enhance, improve and develop new services and products and for overall customer support.
  • To process your order and/or deliver the Products you purchase through our Platform.
  • Monitor usage and interaction statistics on our Platform, and/or through responses to our communications.
  • Perform data analytics for our internal business purposes.
  • Allow us to respond quickly and efficiently to your questions and your requests for information.
  • Communicate with you (via email, text, phone or mail) either directly or indirectly through our marketing service provider to send you special offers, or marketing information related to our products and services.
  • Communicate with you to request feedback or to notify you of changes to our terms, conditions and Privacy Policy.
  • Track use of our Platform, investigate suspicious activity, and enforce our terms and policies, to measure and improve the operation and security of our Platform, and your Personal Information.
  • Assess and improve our Products and Content.
  • Allow us to disclose your information to the extent permitted or required by law.

We use the Usage Information to perform data analytics, analyze and evaluate the features and functionality of our Platform, Content, and Products. We may also use Usage Information to process automatic crash reporting which collects reports of crashes, other technical issues, and information relating to how our Platform is functioning.

We may use Location Information to customize Products, Content or information specific to your region. You have the ability to control access to Location Information through the control settings on your device.

This information may also be provided to our Third-Party ĢƵ (as defined below) as necessary to provide our Platform, Content, and Products, and related functionality and offer other services and products. Our “Third Party ĢƵ” may include, in addition to any of our data sources, software development, application and data hosting, wireless network services providers, payment processors, and any digital analytics or marketing services. We are responsible for assuring that these Third-Party ĢƵ comply with the terms of this Privacy Policy.

Except for our Third-Party ĢƵ, we will not share Personal Information, Usage Information, or Location Information with an unaffiliated third party without your prior authorization, unless doing so is necessary (1) to enforce this Privacy Policy, to comply with law, regulation or other legal processes or to protect the rights, property or safety of us or others, (2) to comply with a valid order or process from a public authority, (3) to protect against misuse or unauthorized use of our Platform or your user account, (4) to detect or prevent criminal activity or fraud, or (5) in the event that we or substantially all of our assets are acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, consolidation or liquidation, in which case such information may be one of the transferred assets.

Your Rights

Depending on where you live, you may have certain legal rights under applicable law. For example, you may have the following rights:

  • Right to Access – means you can ask us for a copy of any Personal Information we have about you, if any.
  • Right to Correct – means you may ask us to change and/or correct any Personal Information we have about you.
  • Right to Delete – means you may ask us to delete any Personal Information we have about you and we will be happy to do so unless we are required to retain such information by law or regulation or we have a right to retain subject to a user agreement for our internal business purposes.
  • Right to Transfer – means you may request a copy of your Personal Information, in a commonly used and machine-readable format, be provided to you or to a third party you specify.
  • Right to Limit – means you have the right at any time to unsubscribe to any marketing communication from us and we will promptly honor such request.

We may update our Privacy Policy from time to time. We encourage you to review our Privacy Policy frequently to stay informed regarding how we collect, use, share and process Personal Information. You may contact us (see the Contact Us section below) at any time about any of these rights or any concern or question you have about our use of your Personal Information. See also the specific laws addendum.

Security

We take precautions to protect your Personal Information, including reasonable physical, administrative, and technical safeguards. When you submit Personal Information via our Platform, your Personal Information is transmitted using secure sockets layer (SSL) encryption technology. We restrict access to your Personal Information to our authorized personnel and/or Third-Party ĢƵ as appropriate and necessary to provide our Platform, Content, Products and/or maintain your user account.

We keep your Personal Information if it is necessary to process your requests, operate our business, and provide our Platform, Content, and Products, or as long as we are legally required to do so. For as long as we have your Personal Information, we will continue to protect the privacy and security of such Personal Information consistent with this Privacy Policy. However, no website, database or system is completely secure or “hacker proof.” You are also responsible for taking reasonable steps to protect your Personal Information against unauthorized disclosure or misuse. You are also responsible for protecting the security of your user account credentials and for any use of your user account.

Children’s Online Privacy Protection Act

In compliance with the Children’s Online Privacy Protection Act, 15 U.S.C. § 6501.06 and 16 C.F.R. §§ 312.1 – 312.12, we do not knowingly collect information from children under the age of 13, nor does our Platform or our Content or Products target children under the age of 13. By using our Platform, Content, Products, and/or creating any user account, you represent that you are not younger than 13. Please contact us as noted below if you know or suspect that we have collected information from children under the age of 13 and we will take prompt measures to remove such information.

Contact Us

If you have any questions, comments, or concerns about this Privacy Policy, please contact us via email at privacy@thinksmallinstitute.org. All emails should include your first name, last name, email address, and the nature of your request.

Copyright © 2021-2024 by ĢƵl. All rights reserved.

Specific Laws Addendum

United States

The following additional terms may apply to you depending on where you reside in the United States. To the extent of any inconsistency, these terms take precedence over the terms in our Privacy Policy in relation to personal information that is collected and/or held in the United States.

Please use the contact information in the Privacy Policy if you wish to access or correct any of your personal information that we hold or if you would like to report a potential breach by us of any applicable laws of the United States, our Privacy Policy, or this Addendum. We will promptly acknowledge and investigate any such reports.

The laws of the states described below are the ones we are currently aware of that require giving individual notice and/or consent with respect to our Platform, Content, or Products, and that provide for specific individual rights with respect to our Platform, Content, or Products. We recognize that other states also have laws that may affect your privacy rights with respect to our Platform, Content, or Products, and we direct you to the information in our Privacy Policy for a description of such rights.

As described further in our Privacy Policy, in the preceding twelve months, we or our service providers may have collected the below categories of personal information for business or commercial purposes:

  • Identifiers (such name, email address, address, and phone number);
  • Commercial information (such as transaction data);
  • Internet or other network or device activity (such as IP address, unique device, advertising ID, browsing history or other usage data);
  • Location information (general location, and, if you provide permission, precise GPS location);
  • Sensory information (such as audio recordings if you call our customer service);
  • Inferences about your preferences and traits through your use of the Platform; and
  • Other information that identifies or can be reasonably associated with you.

We collect the categories of personal information identified above from the following sources: (1) directly from you; (2) through your use of the Platform; (3) affiliates; and (4) third-parties such as other users or our third-party providers.

We or our service providers may collect the categories of information identified above for the following business or commercial purposes (as those terms are defined in applicable law):

  • Our or our service provider’s operational purposes;
  • Auditing consumer interactions on our site (e.g., measuring ad impressions);
  • Detecting, protecting against, and prosecuting security incidents, fraudulent or illegal activity and activity that violates any terms or policies;
  • Bug detection, error reporting, and activities to maintain the quality or safety of our Platform, Content, or Products;
  • Short-term, transient use, such as customizing content that we or our service providers display on services;
  • Providing services (e.g., account servicing and maintenance, data processing, customer service, advertising and marketing, analytics, communication about our Platform, Content, or Products, facilitating communications between users);
  • Improving our existing Products and developing new Products (e.g., by conducting research to develop new products or features, or to train our employees on issues that our users need to be resolved);
  • Other uses that advance our commercial or economic interests, such as third-party advertising and communicating with you about relevant offers from third-party partners;
  • Other uses about which we notify you.

We describe our information sharing practices in the Privacy Policy. In the previous twelve months, we may have shared certain categories of personal information with third-parties for business purposes. The personal information shared may include the following categories of personal information: (1) identifiers; (2) commercial information; (3) location information; and (4) other information that can be associated with you.

Examples of these types of uses are identified below. We may also use the below categories of personal information for compliance with applicable laws and regulations, and we may combine the information we collect (“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent identification of any particular user or device.

Table of Categories of Data, Uses and With Whom Shared

Categories of Personal Information We Collect Examples of Uses Categories of Third Parties With Which We May Share That Information Collected/Shared
Identifiers (e.g., real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name) Providing our Platform, Content, and Products, Updating and improving our Platform, Content, and Products, Personalizing content, Marketing and advertising, Communicating with you, Analyzing your use of our Platform, Preventing, detecting, investigating, and responding to fraud, unauthorized access/use of our Platform, breaches or potential breaches of terms and policies, Internal training of our personnel Affiliates, Third Party ĢƵ Yes
Any personal information described in subdivision (e) of Section 1798.80 (e.g., name, address, telephone number, bank account number, credit card number, debit card number, or any other financial information (with financial information only as required by our Third-Party Provider (i.e., Stripe)) Providing our Platform, Content, and Products, Updating and improving our Platform, Content, and Products, Communicating with you, Analyzing your use of our Platform, Preventing, detecting, investigating, and responding to fraud, unauthorized access/use of our services, breaches or potential breaches of terms and policies, Internal training of our personnel Affiliates, Third Party ĢƵ Yes
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement) Providing our Platform, Content, and Products·, Updating and improving our Platform, Content, and Products, Personalizing content, Marketing and advertising, Analyzing use of our Platform, Preventing, detecting, investigating, and responding to fraud, unauthorized access/use of our services, or breaches or potential breaches of terms and policies Affiliates, Third Party ĢƵ Yes
Geolocation information (general location, and, if you provide permission, precise GPS location) Providing our Platform, Content, and Products, Updating and improving our Platform, Content, and Products, Personalizing content, Marketing and advertising, Analyzing use of our Platform, Preventing, detecting, investigating, and responding to fraud, unauthorized access/use of our services, or breaches or potential breaches of terms and policies Affiliates, Third Party ĢƵ Yes
Sensory information (e.g., audio, electronic, visual, thermal, olfactory, or similar information) Providing our Platform, Content, and Products, Updating and improving our Platform, Content, and Products, Personalizing content, Analyzing use of our Platform, Preventing, detecting, investigating, and responding to fraud, unauthorized access/use of our services, or breaches or potential breaches of terms and policies, Internal training of our personnel Affiliates, Third Party ĢƵ Yes
Professional or employment-related information Providing our Platform, Content, and Products, Updating and improving our Platform, Content, and Products, Analyzing use of our Platform, Preventing, detecting, investigating, and responding to fraud, unauthorized access/use of our services, or breaches or potential breaches of terms and policies, Internal training of our personnel Affiliates,  Third Party ĢƵ Yes
Inferences drawn (to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes) Providing our Platform, Content, and Products, Updating and improving our Platform, Content, and Products, Personalizing content, Analyzing use of our Platform, Preventing, detecting, investigating, and responding to fraud, unauthorized access/use of our services, or breaches or potential breaches of terms and policies Affiliates, Third Party ĢƵ Yes
Sensitive personal information (e.g., account log-in, financial account, debit card, or credit card number with any required security or access code, password, or credentials allowing access to an account; precise geolocation) Financial information is required by our Third-Party Provider for payment processing (i.e., Stripe). The only information provided to us from Stripe is last four digits of card, email, and zip code. Our Third-Party Provider uses to: Process payments for our Products, Updating and improving our Platform, Content, and Products, Analyzing use of our Platform, Preventing, detecting, investigating, and responding to fraud, unauthorized access/use of our services, or breaches or potential breaches of terms and policies Affiliates, Third Party ĢƵ Yes

 

We collect the categories of personal information identified above from the following sources: (1) directly from you; (2) through your use of the Platform; (3) affiliates; and (4) third-parties such as other users or our third-party providers.

For Residents of California

If you are a California resident (as defined by the California Consumer Privacy Act), you may have certain rights.

This Notice for California Residents supplements the information in our Privacy Policy, and except as provided herein, applies solely to California residents (as defined by the California Consumer Privacy Act (CCPA) and amended by the Consumer Privacy Act Regulations (CPRA)). It may apply to personal information (as defined by CCPA / CPRA) we collect on or through the Platform and through other means (such as information collected offline, in person, and over the telephone). Until the CCPA / CPRA has specifically regulated business information, this Notice for California Residents does not apply to business information that does not constitute personal information.

Summary of Information We Collect

California law requires us to disclose information regarding the categories of personal information that we have collected about California consumers, the categories of sources from which we collect personal information, the business or commercial purposes (as each of those terms are defined by applicable law) for which we collect personal information, and the categories of parties with whom we share personal information. See the details as noted above for categories of information and uses.

Rights

If you are a California resident (as defined by the CCPA / CPRA), you may have certain rights. California law may permit you to request that we:

  • Provide you the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information, if applicable (note, at this time we do not sell or share personal information with unaffiliated third parties); and the categories of third-parties with whom we shared personal information.
  • Provide access to and/or a copy of certain information we hold about you.
  • Request to opt-out of the sale or sharing of personal information.
  • Delete certain information we have about you.

You may have the right to receive information about the financial incentives that we offer to you, if any. You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights referenced herein. Certain information may be exempt from such requests under applicable law. In addition, we need certain types of information so that we can provide our Platform, Content, and Products to you. If you ask us to delete it, you may no longer be able to access or use our Platform, Content, or purchase our Products.

If you would like to exercise any of these rights, please submit a request to privacy@thinksmallinstitute.org. You will be required to verify your identity before we are able to fulfil your request. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.

The CCPA / CPRA, sets forth certain obligations for businesses that “sell” personal information. We do not sell personal information.

Metrics

California law may require us to compile the following metrics for the previous calendar year: the number of rights requests received, complied with, and denied, as well as the median number of days within which we responded to those requests. To the extent this obligation applies to us, we will update this section.

California Shine the Light

If you are a California resident, you may ask for a list of third-parties that have received your information for direct marketing purposes during the previous calendar year. If we have shared your information, this list will contain the types of information shared, and we will provide this list at no cost. To make such a request, contact us at privacy@thinksmallinstitute.org.

California Do-Not-Track Disclosure

We are committed to providing you with meaningful choices about the information collected on our Platform for third-party purposes. However, we do not currently recognize or respond to browser-initiated Do-Not-Track signals, as the Internet industry is currently still working on Do-Not-Track standards, implementations, and solutions.

For Residents of Colorado

If you are a resident of Colorado and you meet the definition of a “consumer,” you may have certain rights.

Summary of Information We Collect

Colorado law requires us to disclose information regarding the categories of personal data that we have collected about Colorado consumers, the categories of sources from which we collect personal information, the business or commercial purposes (as each of those terms are defined by applicable law) for which we collect personal information, and the categories of parties with whom we share personal information. See the details as noted above for categories of information and uses.

Rights

Colorado law may permit you to request that we act on a consumer’s following rights:

  • Right of access to and/or a copy of certain information we hold about you.
  • Right to correct for any inaccuracies in your personal data.
  • Right to request that we delete your personal data.
  • Right to obtain your personal data in a portable (and if technically feasible readily usable) format.
  • Right to request to opt-out of the sale of personal data, targeted advertising, or profiling in furtherance of decisions that produce legal or similarly significant effects. We do not currently sell personal data or engage in profiling.

If you would like to exercise any of these rights, please submit a request to privacy@thinksmallinstitute.org. You will be required to verify your identity before we are able to fulfill your request. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.

Please note that while we may record customer service calls and/or training videos; we do not digitally analyze any such data for any biometric identification purposes.

For Residents of Connecticut

If you are a resident of Connecticut and you meet the definition of a “consumer,” you may have certain rights.

Summary of Information We Collect

Connecticut law requires us to disclose information regarding the categories of personal data that we have collected about Connecticut consumers, the categories of sources from which we collect personal information, the business or commercial purposes (as each of those terms are defined by applicable law) for which we collect personal information, and the categories of parties with whom we share personal information. See the details as noted above for categories of information and uses.

Rights

Connecticut law may permit you to request that we act on a consumer’s following rights:

  • Right of access to and/or a copy of certain information we hold about you.
  • Right to correct for any inaccuracies in your personal data.
  • Right to request that we delete your personal data.
  • Right to obtain your personal data in a portable (and if technically feasible readily usable) format.
  • Right to request to opt-out of the sale of personal data, targeted advertising, or profiling in furtherance of decisions that produce legal or similarly significant effects. We do not currently sell personal data or engage in profiling.

If you would like to exercise any of these rights, please submit a request to privacy@thinksmallinstitute.org.  You will be required to verify your identity before we are able to fulfil your request. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.

Please note that while we may record customer service calls and/or training videos; we do not digitally analyze any such data for any biometric identification purposes.

For Residents of Illinois

Rights

Residents of Illinois may have certain rights under the Biometric Information Privacy Act. Please note that while we may record customer service calls and/or training videos; we do not digitally analyze any such data for any biometric identification purposes.

For Residents of Nevada

Rights

Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration to a person for that person to license or sell such information to additional persons. “Personally identifiable information” includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a person to be contacted either physically or online.

We do not engage in such activity.

For Residents of Virginia

If you are a resident of Virginia and you meet the definition of a “consumer,” you may have certain rights.

Summary of Information We Collect

Virginia law requires us to disclose information regarding the categories of personal data that we have collected about Virginia consumers, the categories of sources from which we collect personal information, the business or commercial purposes (as each of those terms are defined by applicable law) for which we collect personal information, and the categories of parties with whom we share personal information. See the details as noted above for categories of information and uses.

Rights

Virginia law may permit you to request that we act on a consumer’s following rights:

  • Right to confirm if we are processing personal data we hold about you.
  • Right to correct for any inaccuracies in your personal data.
  • Right to request that we delete your personal data.
  • Right to obtain your personal data in a portable (and if technically feasible readily usable) format.
  • Right to request to opt-out of the sale of personal data, targeted advertising, or profiling in furtherance of decisions that produce legal or similarly significant effects. We do not currently sale personal data or engage in profiling.

If you would like to exercise any of these rights, please submit a request to privacy@thinksmallinstitute.org. You will be required to verify your identity before we are able to fulfil your request. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.

Please note that while we may record customer service calls and/or training videos; we do not digitally analyze any such data for any biometric identification purposes.

For Residents of Utah

If you are a resident of Utah and you meet the definition of a “consumer,” you may have certain rights.

Summary of Information We Collect

Utah law requires us to disclose information regarding the categories of personal data that we have collected about Utah consumers, the categories of sources from which we collect personal information, the business or commercial purposes (as each of those terms are defined by applicable law) for which we collect personal information, and the categories of parties with whom we share personal information. See the details as noted above for categories of information and uses.

Rights

Utah law may permit you to request that we act on a consumer’s following rights:

  • Right to confirm if we are processing personal data we hold about you.
  • Right to correct for any inaccuracies in your personal data.
  • Right to request that we delete your personal data.
  • Right to obtain your personal data in a portable (and if technically feasible readily usable) format.
  • Right to request to opt-out of the sale of personal data, targeted advertising, or profiling in furtherance of decisions that produce legal or similarly significant effects. We do not currently engage in the sale of personal data or engage in profiling.

If you would like to exercise any of these rights, please submit a request to privacy@thinksmallinstitute.org. You will be required to verify your identity before we are able to fulfil your request. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.

Non-US Country Addendum

EU/EEA

The following additional terms apply to you if you reside in the European Union/European Economic Area (EU/EEA). To the extent of any inconsistency, the following terms take precedence over the terms in our Privacy Policy in relation to personal data that is collected and/or held relating to individuals (i.e., data subjects) residing in the EU/EEA.

The EU/EEA’s General Data Protection Regulation (GDPR) governs our processing (as defined under GDPR) of your personal data, as well as your rights regarding the same. As used in this Addendum, the following terms have the following meanings:

“Breach”, “data controller”, “data processor”, “Data Protection Authority”, “data subject”, “data subject rights”, “Member State”, “personal data”, “personal data breach”, “processing” (and “process”) (regardless of whether capitalized herein) have the meanings given to them in GDPR.

“Standard Contractual Clauses,” for purposes of our Privacy Policy, means the template agreement contained in the Annex of the European Commission’s Implementing Decision of 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council, and any replacement, amendment or restatement of the foregoing issued by the European Commission.

Data controller; processing

ĢƵl is a data controller of your personal data. GDPR sets forth specific obligations of a data processor and data controller in each of these roles.

Lawful Basis for our Processing of Your Personal Data.

As the data controller, we are responsible for establishing a lawful basis for the processing of your personal data. We rely on our legitimate interests under GDPR Article 6 in order to engage in the processing of your personal data. This means that we have a legitimate interest in receiving and processing your personal data in order to provide our Platform, Content, and Products. We may, in some cases, also rely on obtaining your consent under GDPR Article 6 as the lawful basis of their processing of your personal data. If so, this means that we have requested your explicit consent (or “opt-in”) to their processing of your personal data.

Data Protection Officer.

ĢƵl has appointed a Data Protection Officer (DPO).

Individual Rights

As also noted in our Privacy Policy, you may make the following requests from us as the data controller. In each case these rights are subject to restrictions and/or exceptions as specified in the GDPR. The following is a summary of your rights:

  • The right of access, enabling you to receive a copy of your personal data
  • The right to rectification, enabling you to correct any inaccurate or incomplete personal data we hold about you
  • The right to erasure, enabling you to ask us to delete your personal data in certain circumstances
  • The right to restrict processing, enabling you to ask us to halt the processing of your personal data in certain circumstances
  • The right to object, enabling you to object to us processing your personal data on the basis of our legitimate interests (or those of a third party), and
  • The right to data portability, enabling you to request us to transmit personal data that you have provided to us to a third party without hindrance, or to give you a copy of it so that you can transmit it to a third party, where technically feasible.

Under GDPR, a data subject also has the right to lodge a complaint with a Data Protection Authority, in particular in the Member State of the data subject’s residence, place of work or place of an alleged infringement, if the data subject considers that the processing of the personal data infringes the GDPR.

If you wish to exercise any of these rights, please contact us using the contact information provided in our Privacy Policy. Please note that the GDPR specifies when the data controller may refuse your request where there is a basis to do so in law, or if your request is manifestly unfounded or excessive.

Special Categories of Personal Data

Our Platform does not require the collection or processing of any sensitive personal data or sensitive information, as defined in applicable data protection laws (e.g., racial, ethnical origin, political opinions, religious beliefs, etc.). We may nevertheless collect such sensitive personal data about you or we may collect it incidentally if you provide such data to us. By providing any sensitive personal data or by providing information by a recording, you consent to our collection of such information, however, we do not require or use such data to provide our Platform, Content, or Products.

International Transfers of Data

Personal Information originating in the EU/EEA will generally be stored on servers in the EEA but may be accessed and/or processed in a limited manner outside of the EEA. We adhere to the GDPR where it applies to our Platform, Content, or Products. Where your personal data is processed outside of the EEA, we will put in place appropriate safeguards. Where appropriate, we may enter into Standard Contractual Clauses with importers or processors and/or other relevant third parties for the transfer of your personal data and may carry out a risk assessment and/or take necessary security measures in order to fulfill our obligations under GDPR.

If we determine we are unable to provide equivalent protection of your personal data, including by entry into the Standard Contractual Clauses, we may seek to rely on derogations authorized by the GDPR, including the derogation of consent/contract/request of data subject. If relying on your consent, we will seek your explicit consent in advance.

United Kingdom

The following additional terms apply to you if you reside in the United Kingdom (UK). To the extent of any inconsistency, these terms take precedence over the terms in our Privacy Policy in relation to personal data that is processed in the UK.

The UK’s General Data Protection Regulation (UK GDPR) governs our processing (as defined therein) of your personal data, as well as your rights regarding the same. As used in this Addendum, the following terms have the following meanings:

“Breach”, “data controller”, “data processor”, “Information Commissioner’s Office (ICO)”, “data subject”, “data subject rights”, “personal data”, “personal data breach”, “processing” (and “process”) (regardless of whether capitalized herein) have the meanings given to them in the UK GDPR. The UK GDPR may regard a video as “personal data” if the image can be used to identify you.

“UK Addendum” means the International Data Transfer Addendum to the EU/EEA Standard Contractual Clauses issued by the ICO, version B1.0 in force March 21, 2022, as may be amended from time to time (or any successor version).

Data controller; processing

ĢƵl is a data controller of your personal data. The UK GDPR sets forth specific obligations of data controllers and processors in each of these roles.

Lawful Basis for our Processing of Your Personal Data.

Because we are a data controller, we are the ones who are responsible for establishing a lawful basis for the processing of your personal data. We rely on our legitimate interests under UK GDPR Article 6 in order to engage in the processing of your personal data. This means that we have a legitimate interest in receiving and processing your personal data in order to provide the Platform, Content, and Products. We might in some cases also rely on obtaining your consent under UK GDPR Article 6 as the lawful basis of our processing of your personal data. If so, this means that we have requested your explicit consent (or “opt-in”) to their processing of your data. If applicable, you will be provided with our Consent and/or Lawful Basis to Collection and Processing of Personal Data notice.

Data Protection Officer.

ĢƵl has appointed a Data Protection Officer (DPO) as specified in our Privacy Policy.

Individual Rights

As also noted in our Privacy Policy, you may make the following requests from us as the data controller. In each case these rights are subject to restrictions and/or exceptions as specified in the UK GDPR. The following is a summary of your rights:

  • The right of access, enabling you to receive a copy of your personal data
  • The right to rectification, enabling you to correct any inaccurate or incomplete personal data we hold about you
  • The right to erasure, enabling you to ask us to delete your personal data in certain circumstances
  • The right to restrict processing, enabling you to ask us to halt the processing of your personal data in certain circumstances
  • The right to object, enabling you to object to us processing your personal data on the basis of our legitimate interests (or those of a third party), and
  • The right to data portability, enabling you to request us to transmit personal data that you have provided to us to a third party without hindrance, or to give you a copy of it so that you can transmit it to a third party, where technically feasible.

You have the right to lodge a complaint with the ICO if you consider that the processing of your personal data infringes the UK GDPR. If you wish to exercise this right, please contact us. You may also contact us using the contact information provided in our Privacy Policy. We have the right to refuse your request where there is a basis to do so in law, or if your request is manifestly unfounded or excessive.

Special Categories of Personal Data

Our Platform does not require the collection or processing of any sensitive personal data or sensitive information, as defined in applicable data protection laws (e.g., racial, ethnical origin, political opinions, religious beliefs, etc.). We may nevertheless collect such sensitive personal data about you or we may collect it incidentally if you provide such data to us. By providing any sensitive information or by providing information by recording, you consent to our collection of such information and our use and disclosure of it in accordance with our Privacy Policy for purposes directly related to the reason it was provided.

International Transfers of Data

Personal Information originating in the UK will be stored on servers in the UK but may be accessed and/or processed in a limited manner outside of the UK. We adhere to the UK GDPR where it applies to our Platform. Where your data is processed outside of the UK, we have put in place appropriate safeguards. Where appropriate, we may enter into the UK Addendum to the Standard Contractual Clauses with an importer or processor and/or other relevant third parties for the transfer of your personal data and may carry out a risk assessment and/or take necessary security measures in order to fulfill our obligations under the UK GDPR.

If we determine we are unable to provide equivalent protection of your personal data, including by entry into the UK Addendum to the Standard Contractual Clauses, we may seek to rely on derogations authorized by the UK GDPR, including the derogation of consent/contract/request of data subject. If relying on your consent, we will seek your explicit consent in advance.

Canada

The following additional terms apply to you if you reside in Canada. To the extent of any inconsistency, these terms take precedence over the terms in our Privacy Policy in relation to personal information that is collected and/or held in Canada.

Applicable Law

At the Canadian federal level, the Personal Information Protection and Electronic Documents Act (PIPEDA) establishes a framework for the collection and use of your personal information across Canada (e.g., if you are a candidate for employment of an organization that is a federally regulated work, undertaking, or business (e.g., Canadian bank, airline, broadcaster, etc.)). PIPEDA may not apply to personal information about you for use of our Platform.

If PIPEDA does not apply, Canadian provincial privacy laws may still apply. We will comply with any such specific provincial privacy laws that apply to our Platform, Content, or Products. For example, Alberta, British Columbia, and Quebec may have provincial privacy laws that apply to your personal information.

Consent

Depending on the applicable data protection laws, we may need to obtain your consent for the collection, use, or disclosure of your personal information. In Canada, your consent is only valid if it is reasonable to believe that you understand the nature, purpose, and consequences of the collection, use, or disclosure of your personal information. You may withdraw your consent at any time.

At the time of obtaining your consent, we must provide you with the following:

  • An exhaustive list of types of personal information being collected and processed
  • A list of third parties with whom it is being shared (including the countries for such parties if outside Canada)
  • A stated commitment to handling your personal information according to our Privacy Policy, and provide a link to that policy
  • An explanation of the risk of harm and other potential consequences in using our Platform
  • A “No, I do not consent” button or similar option and explain to you the consequences of withholding your consent, and
  • A statement of the possibility for you to withdraw your consent after providing it.

If applicable, you will be provided with our Consent and/or Lawful Basis to Collection and Processing of Personal Data notice.

Opting Out of Email Communications

Canada’s Anti-Spam Legislation (CASL) requires your consent on an opt-in basis in order for us to communicate with you by email. If you elect to provide us with an email address, we will treat such provision as your consent to opt-in to our use of email as a communication means. If applicable, you will be provided with our Consent and/or Lawful Basis to Collection and Processing of Personal Data notice. You may opt-out of email communication at any time.

 

Acceptable Use Policy

Last updated: May 17, 2024

This Acceptable Use Policy (“AUP”) applies to any user, strategic partner, customer or vendor with use rights to any of the ĢƵl data, system, or technology used to provide the ĢƵl platform (“TS Technology”) or its website or platform (“TS Platform”). Any such user, strategic partner, customer or vendor, acknowledges and agrees that any use rights or license grant which may be provided in an underlying agreement with ĢƵl is governed by the restrictions in this AUP. The TS Technology and TS Platform may be used solely for its/his/her internal business/personal purposes (as applicable). The TS Technology and TS Platform may not be used to:

  • Send spam or any other form of duplicative and unsolicited messages, or any other mass communication other than as expressly permitted by ĢƵl;
  • Harvest, collect, gather or assemble information or data regarding other users of the TS Platform without their consent;
  • Transmit through or post on the TS Platform unlawful, libelous, tortuous, infringing, defamatory, threatening, vulgar, or obscene material or material that may be harmful to minors;
  • Knowingly transmit material containing software viruses or other harmful or deleterious computer code, files, scripts, agents, or programs;
  • Knowingly interfere with or disrupt the integrity or performance of the website or the data contained therein or attempt to gain unauthorized access to the service, computer systems or networks related to the TS Platform;
  • Decompile, disassemble, or otherwise reverse engineer or attempt to reconstruct or derive any source code (or underlying ideas, algorithms, structure or organization) from any TS Technology or TS Platform or from any other information by any means whatsoever;
  • Distribute, disclose or allow use of any of the TS Technology or TS Platform in any format through any timesharing device, service bureau, network or by any other means, to or by any third party (not including affiliates if permitted under an underlying agreement);
  • Violate any use or license grant, as specified in the underlying agreement;
  • Create Internet “links” to or from the TS Platform, or “frame” or “mirror” any of ĢƵl’s content which forms part of the TS Platform (other than on customers’ own internal intranets as permitted by an underlying agreement); or
  • Modify or create a derivative work of the TS Technology or TS Platform or any portion thereof.

 

We reserve the right to investigate any suspected violations of this AUP. We may also report suspected violations of this AUP to applicable law enforcement authorities or third parties and we may elect to cooperate with any investigation of illegal activities associated with violations or suspected violations of this AUP, TS Technology or TS Platform.

If you have any concerns or questions about this AUP, please contact us at: privacy@thinksmallinstitute.org.

Copyright © 2021-2024 ĢƵl. All rights reserved.

 

ĢƵl End User License Agreement (EULA)

Last updated: May 17, 2024

In addition to the general Terms & Conditions (“Terms”), found online here, and which are deemed incorporated herein by this reference, you acknowledge and agree that any Product(s) that you access, use, or download from ĢƵl’s Platform are subject to these additional end user license agreement terms (“EULA”). Capitalized terms not defined in this EULA shall have the meaning set forth in the Terms.

By accessing, using, or downloading any Product(s), including whether you click “ACCEPT” on any notice prior to download, or you receive a copy of this EULA with any signed order form or purchase order for the Product(s) you: (a) acknowledge that you have read and understand this EULA and the Terms; (b) represent and warrant that you are 18 years of age or older; and (c) are authorized to and you do accept this EULA and the Terms and agree that you are legally bound by this EULA and the Terms. If you do not agree to all of this EULA and the Terms, do not access, download, or use the Product(s). For purposes of this EULA, “you” includes yourself and any organization or legal entity for which you are acquiring the Product(s), or from whose equipment the Product(s) will be downloaded or used.

This EULA may be modified from time to time, and such modifications shall be effective immediately upon posting of the modified EULA. Your continued use of the Product(s) will mean you accept the modified EULA as of the last revised date noted above.

License.  We hereby grant you a limited, non-exclusive, revocable, non-transferable right to download, install, and use the Product(s) for your personal, non-commercial use on a single device owned or otherwise controlled by you, strictly in accordance with the Terms and this EULA.

Limitations on Your Rights.  You shall have no right to make or use additional copies of the Product(s). Your access to any of our documentation is solely for your use with the Product(s). Without our prior written consent, you may not rent, lease, lend, sell, sublicense, assign, publish, copy, reproduce, distribute, transfer, upload, post, transmit, or otherwise make available, in whole or in part, the Product(s), or any content, features, or functionality contained on or provided through the Product(s) to any third party for any reason, including by making the Product(s) available on a network where it is capable of being accessed by more than one device at a time. Requests for our permission to publish, copy, reproduce, distribute, transfer, or otherwise use such content may be sent to us using the contact us option found in our Privacy Policy or on our website. Your use of any downloaded version of our Product(s) is subject to compliance with: (i) the Restrictions noted in the Terms; (ii) our Acceptable Use Policy; and (iii) your consent that you shall not remove, obscure, or alter any proprietary rights notices (including copyright and trademark notices) which may be affixed to or contained within the Product(s).

Confidentiality.  You shall hold all nonpublic information and/or content in the Product(s) as “Confidential Information” and in trust and confidence. You further agree that such Confidential Information shall be used solely for your personal use of the Product(s), and it shall not be disclosed to any third party under any circumstances whatsoever. You shall use a reasonable standard of care to prevent unauthorized disclosure, use, or publication of such Confidential Information or any unauthorized use of the Product(s). You agree to promptly notify us in the event of any breach of your obligations under this EULA.

Product Updates.  The license provided hereunder is only to the Product(s) in their current form and does not include any rights to any updated versions that we may offer in the future. You may separately purchase updated versions of the Product(s).

Compliance with Applicable Laws.  You agree that you will not use the Product(s) for activities prohibited by state or federal law or other applicable rules or regulations.

Indemnification.  You agree to indemnify, defend, and hold harmless us and our officers, directors, employees, agents, licensors, suppliers, successors and assigns from any liability, loss, claim, action, demand, and expense (including reasonable attorneys’ fees) resulting from, or alleged to result from, your violation or breach of this EULA.

Agreement.  The Terms and this EULA, including any order form, purchase order or supplemental terms we agree to in writing, constitute the entire agreement and understanding between you and us with respect to the subject matter hereof and supersedes all prior agreements, understandings, inducements and conditions expressed or implied, oral or written, of any nature whatsoever with respect to the subject matter hereof. This EULA shall be binding upon and inure to the benefit of you and us and our successors and assigns.

No Waiver; Severability.  Our failure to insist upon strict enforcement of any provision(s) of this EULA shall not be construed as a waiver of any provision or right. Should any provision of this EULA be held invalid or unenforceable, such invalidity will not invalidate the whole of this EULA, but rather that invalid provision will be amended to achieve as nearly as possible the same economic effect as the original provision and the remainder of this EULA will remain in full force and effect.

YOU EXPRESSLY ACKNOWLEDGE THAT YOU HAVE READ THE TERMS AND THIS EULA AND UNDERSTAND THE RIGHTS, OBLIGATIONS, TERMS AND CONDITIONS SET FORTH HEREIN. BY CLICKING ON THE “ACCEPT” BUTTON OR DOWNLOADING, INSTALLING OR USING THE PRODUCT(S), YOU EXPRESSLY CONSENT TO BE BOUND BY THE TERMS AND CONDITIONS OF THE TERMS AND THIS EULA.

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