Privacy Policy

CPEP operates a group of social learning networks for students and educators. ("CPEP", "we", "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how your personal information is collected, used and disclosed by CPEP. This Privacy Policy applies to our websites and service offered at cpep.org (collectively, the "Service"). By accessing or using our Service, you signify that you have read, understood and agree to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy and our Terms of Service.

For the purposes of EU data protection laws ("Data Protection Law"), CPEP is data controller (i.e., the company who is responsible for, and controls the processing of, your personal data).

WHAT INFORMATION DO WE COLLECT AND FOR WHAT PURPOSE?

The categories of information we collect can include:

Information you provide to us directly. We may collect personal information, such as your name, address, date of birth and e-mail address when you register for our Service, sign up for our mailing list, enter a contest or sweepstakes, or otherwise communicate with us. We may also collect any communications between you and CPEP and any other information you provide to CPEP.
Data collected through the use of the Service. We collect information about how you use the Service, your actions on the Service, and content you post to the Service, including the groups you belong to, your interaction with others on the Service, and content you post to the Service, and any content you provide through messages, chat, or other functionality ("User Content"). Please remember that CPEP may, but has no obligation to, monitor, record, and store User Content in order to protect your safety or the safety of other users, to assist with regulatory or law enforcement efforts, or to protect and defend our rights and property. By using the Service, you consent to the recording, storage and disclosure of such communications you send or receive for these purposes.

We use this information above to operate, maintain, and provide to you the features and functionality of the Service, complete transactions or services requested by you, tailor our programming and services to meet your needs and interests, as well as to communicate directly with you, such as to send you email messages. We may also send you Service-related emails or messages (e.g., account verification, change or updates to features of the Service, technical and security notices). For more information about your communication preferences, see "Control Over Your Information" below.

If you choose not to provide personal data, we may not be able to provide the Service to you or respond to your other requests.

LEGAL BASIS FOR PROCESSING IN THE EU

In the EU, the purposes for which we process your personal data are:

where we need to perform the contract we are about to enter into or have entered into with you for the Service;
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
Where we need to comply with a legal or regulatory obligation in the EU.

We have set out in the table at Annex 1 a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. Please contact us at https://cpep.org/index.php?do=feedback if you need details about the specific legal basis we are relying on to process your personal data where more than one legal basis has been set out.

HOW WE USE COOKIES AND OTHER TRACKING TECHNOLOGY TO COLLECT INFORMATION

We and our third party service providers may collect certain types of usage information when you visit our Service, read our emails, or otherwise engage with us. We use this information to enhance and personalize your user experience, to monitor and improve our websites and services, and for other internal purposes. In some instances, we and our third party service providers may combine this usage information with Personal Information. If we do combine any usage information with Personal Information, the combined information will be treated by us as Personal Information hereunder (as long as it is so combined).

We typically collect this information through a variety of tracking technologies, including cookies, web beacons, Locally Stored Objects (LSOs such as Flash or HTML5), log files, and similar technology (collectively, "tracking technologies"), and may use third party providers to collect this information on our behalf. For example, we use tracking technologies to automatically collect information about how you access and use the Service (e.g., referring / exit pages and URLs, how frequently you access the Service, the pages you view, the links you click, and other actions you take on the Service); information about your browser and information about the device(s) you use to access the Service (e.g., Internet Protocol (IP address), browser type, browser language, Internet service provider, device type, model and manufacturer, a unique ID that allows us to uniquely identify your browser, device or account, operating system brand and model, and whether you access the Service from multiple devices); information about your location (e.g., GPS coordinates (e.g., latitude and/or longitude) or similar information or we may be able to approximate or infer a device’s location by analyzing other information, like an IP address). We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users. You can learn more about Google’s practices at https://www.google.com/policies/privacy/partners. We may also work with third party partners to employ technologies, including the application of statistical modeling tools, which attempt to recognize you across multiple devices. Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time.

We use or may use the data collected through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) identify and contact you across multiple devices; (d) provide and monitor the effectiveness of our Service; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our Service; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our Service.

Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some features and services (particularly those that require you to sign in) may not function properly if your cookies are disabled. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. Deleting cookies does not prevent the collection of information through non-cookie technologies and does delete Local Storage Objects (LSOs) such as Flash objects and HTML5. You can learn more about Flash objects - including how to manage privacy and storage settings for Flash cookies – on Adobe’s website or by clicking here. If you choose to delete Flash objects from our sites, then you may not be able to access and use all or part of the sites or benefit from the information and services offered.

We and our third party partners may also use cookies and tracking technologies for advertising purposes. For more information about tracking technologies, please see "Third Party Tracking and Online Advertising" below.

SHARING OF YOUR INFORMATION

We may share your personal information in the instances described below. For further information on your choices regarding your information, see the "Control Over Your Information" section below.

Remember, our Service allows you to connect and interact with others. Your profile information and other personal information, will be available publicly to other members of the Service by default when you create a profile, interact with others on the Service in public groups, and post content to public spaces.

We may share your personal information with:

The public and other members of the Service. Your content and comments you post to public areas of the Service will be viewable by others on the Service and the public. Please do not provide personal information you would not want to be public. You may be able to control the visibility of some of your information and actions in your Settings (see "Control Over Your Information" below);

Other users of the Service. We share your information with third parties with whom you communicate with on the Service;
Third parties at your request. For example, you may have the option to share your activities on CPEP with your friends through email, text or on various social media sites;
Other companies and brands owned or controlled by CPEP, and other companies owned by or under common ownership as CPEP, which also includes our subsidiaries (i.e., any organization we own or control). These companies will use your personal information in the same way as we can under this Policy.;
Third parties with whom we partner to provide contests and sweepstakes, which will usually be identified by name in the Official Rules of the contest or sweepstakes;
Third-party vendors and other service providers that perform services on our behalf, as needed to carry out their work for us, which may include identifying and serving targeted advertisements, providing mailing services, providing tax and accounting services, contest fulfillment, web hosting, or providing analytic services;
The public when you provide feedback or user content on our site. For example, if you post user content to the Service or comment on our social media sites, your information, such as your first name, last initial, state of residence, and your comments, may be displayed on our Service or on our social media pages;
Other parties in connection with a company transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party, or in the event of a bankruptcy or related or similar proceedings; and
Third parties as required by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Service or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of CPEP, our visitors, or others.
We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.

CONTROL OVER YOUR INFORMATION

Profile and Data Sharing Settings. You may update your profile information, such as your email and password, and may change some of your data sharing preferences on your Account Preferences page.

How to control your communications preferences: You can stop receiving promotional email communications from us by clicking on the "unsubscribe link" provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Service, technical and security notices).

Modifying or deleting your information: If you have any questions about reviewing, modifying, or deleting your information, or if you want to remove your name or comments from our Service or publicly displayed content, you can contact us directly at https://cpep.org/index.php?do=feedback. We may not be able to modify or delete your information in all circumstances.

YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION

If you are located in the EU or Switzerland, you have the following rights in respect of your personal data that we hold:

Right of access. The right to obtain access to your personal data.
Right to rectification. The right to obtain rectification of your personal data without undue delay where that personal data is inaccurate or incomplete.
Right to erasure. The right to obtain the erasure of your personal data without undue delay in certain circumstances, such as where the personal data is no longer necessary in relation to the purposes for which it was collected or processed.
Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal data in certain circumstances, such as where the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of that personal data.
Right to portability. The right to portability allows you to move, copy or transfer personal data easily from one organization to another.
Right to object. You have a right to object to processing based on legitimate interests and direct marketing.

If you wish to exercise one of these rights, please contact us using the contact details at the end of this Privacy Policy.

You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

THIRD PARTY TRACKING AND ONLINE ADVERTISING

We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your online browsing history and your interests. We permit third party online advertising networks, social media companies and other third party services, to collect, information about your use of our Service over time so that they may play or display ads on our Service, on other websites, apps or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through cookies or similar tracking technologies. We may share a common account identifier (such as an email address or user ID) or hashed data with our third party advertising partners to help identify you across devices. We and our third party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.

To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://optout.networkadvertising.org/?c=1, and/or the DAA’s resources at http://optout.aboutads.info/?c=2&lang=EN. You may also be able to set your browser to delete or notify you of cookies by actively managing the settings on your browser or mobile device. Please note that some advertising opt-outs may not be effective unless your browser is set to accept cookies. Furthermore, if you use a different device, change browsers or delete the opt-out cookies, you may need to perform the opt-out task again.

You may also be able to limit certain interest-based mobile advertising through the settings on your mobile device by selecting "limit ad tracking" (iOS) or "opt-out of interest based ads" (Android).

Google Analytics and Advertising. We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by vising NAI’s online resources at http://optout.networkadvertising.org/?c=1.

HOW WE STORE AND PROTECT YOUR INFORMATION

Data storage and transfer: Your information collected through our Service may be stored and processed in the United States or any other country in which CPEP or its affiliates or service providers maintain facilities. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and we will take all steps reasonably necessary to ensure that any personal data are treated securely and in accordance with this Privacy Policy. Such transfers are made pursuant to appropriate safeguards.

CPEP has entered into EU standard contractual clauses for intra-group transfers of personal data.

If you wish to enquire further about the safeguards used or if you would like to request a copy of these Model Contracts please contact: https://cpep.org/index.php?do=feedback.

Keeping your information safe: We care about the security of your information and uses commercially reasonable physical, administrative, and technological safeguards to preserve the integrity and security of all information collected through our Service. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

For individuals based in the EU or Switzerland, we store personal data for as long as necessary to fulfill the purposes for which we collect the data (see above under "WHAT INFORMATION DO WE COLLECT AND FOR WHAT PURPOSE?"), except if required otherwise by law.

CHILDREN’S PRIVACY

CPEP does not knowingly collect or solicit any information from anyone under the age of 13 on this Service. In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under 13, please contact us at https://cpep.org/index.php?do=feedback.

LINKS TO OTHER WEB SITES AND SERVICES

The Service may contain links to and from third party websites of our business partners, advertisers, and social media sites and our users may post links to third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the websites of third party sites.

HOW TO CONTACT US

If you have any questions about this Privacy Policy or the Service, please contact us at https://cpep.org/index.php?do=feedback.

CHANGES TO OUR PRIVACY POLICY

We may modify or update this Privacy Policy from time to time to reflect the changes in our business and practices, and so you should review this page periodically. When we change the policy in a material manner we will let you know and update the "last modified" date at the bottom of this page. If you object to any changes, you may close your account. Continuing to use our Service after we publish changes to this Privacy Policy means that you are consenting to the changes.

This Privacy Policy was last modified on 4 June 2020.

Annex 1

Legal basis for processing in the EU

Category of personal information	Purpose / Activity (defined in Section 1 above)	Lawful basis for processing including basis of legitimate interest
Contact information and basic personal details such as your first name, last name, e-mail address and date of birth.	We use this information to operate, maintain and provide to you the features of the Service.	The processing is necessary for: the performance of a contract and to take steps prior to entering into a contract; and our legitimate interests, namely administering the Service, for marketing purposes and communicating with users.
	We use this information to communicate with you, including sending Service-related communications (such as invoices and information about updates to the Service, and any news, alerts and marketing communications (in line with your settings and options)).	The processing is necessary for: the performance of the contract and to take steps prior to entering into a contract; and our legitimate interests, namely administering the Service, for marketing purposes and communicating with users.
	We use this information to deal with enquiries and complaints made by or about you relating to the Service.	The processing is necessary for our legitimate interests, namely administering the Service, for marketing purposes and communicating with users.
Information about how you access and use the Service including, for example, how frequently you access the Service, the time you access the Service and how long you use the Service for, whether you access the Service from multiple devices, the website from which you came and the website to which you go when you leave the Service, and other actions you take on the Service.	We use this information to present the Service to you on your device.	The processing is necessary for our legitimate interests, namely to tailor the Service to the user and improve the Service generally.
	We use this information to administer the Service for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, and to help us develop new products and services.	The processing is necessary for our legitimate interests, namely communicating with users and responding to queries, complaints, and concerns, and for developing and improving the Service.
	We use this information to detect and prevent fraud.	The processing is necessary for our legitimate interests, namely the detection and prevention of fraud.
Content you post to the Service including any content you provide through messages, chat, or other functionality.	We use this information to operate, maintain and provide to you the features of the Service.	The processing is necessary for our legitimate interests, namely administering the Service.
	We use this information to improve the Service.	The processing is necessary for our legitimate interests, namely for developing and improving the Service.