1. What Data We Get

We collect data from you directly, such as information you enter and data about your consumption of content, as well as data from third-party platforms you connect with Allgreenivy. We also automatically collect data, such as information about your device and how you use our services. All of this data is subject to the following processing activities: collecting, recording, organizing, storing, modifying, retrieving, encrypting, pseudonymizing, deleting, combining, and transmitting.

 

1.1 Data You Provide to Us

We may collect different data from or about you depending on how you use the Services. Below are some examples to help you understand better the data we collect.

When you create an account and use the Services, including through a third-party platform, we collect any data you provide directly, including:

Category of Personal Data	Description	Legal Basis for Processing
Account Data	To use certain features, like accessing content, you need to create a user account which requires us to collect and store your email address, password, and account settings. To create an instructor account, we will need your name, email address, password, and account settings. You may also be prompted to provide additional information like your occupation, government ID information, a verification photo, date of birth, race/ethnicity, skill interests, and phone number. Upon creating an account, we will assign you a unique identifying number.	·         Performance of contract ·         Legitimate interests (service provisioning, identity verification, fraud prevention and security, communication)
Profile Data	You have the option to provide additional profile information, such as a photo, headline, biography, language, website link, social media profiles, country, or other data. This profile information, referred to as “Profile Data,” will be visible to others.	·         Performance of contract ·         Legitimate interests (enhanced platform functionality, convey content source information)
Shared Content	Some parts of the service allow you to interact with other users or share content publicly, including by uploading courses and other educational content, posting reviews, asking or answering questions, sending messages to students or instructors, or posting photos or other work you have uploaded. This shared content may be visible to others depending on where it is posted.	·         Performance of contract ·         Legitimate interests (service provisioning, enhanced platform functionality)
Learning Data	When you access content, we collect data including which courses, assignments, labs, workspaces, and quizzes you have started and completed; content and subscription purchases and credits; subscriptions; completion certificates; your interactions with instructors, teaching assistants, and other students; and essays, answers to questions, and other items submitted as part of course requirements.	·         Performance of contract ·         Legitimate interests (service provisioning, enhanced platform functionality)
Student Payment Data	If you make purchases, we collect certain data about your purchase (such as your name, billing address, and ZIP code) as necessary to process your order and which may optionally be saved to process future orders. You must provide certain payment and billing data directly to our payment service providers, including your name, credit card information, billing address, and ZIP code. We may also receive limited information, like the fact that you have a new card and the last four digits of that card, from payment service providers to facilitate payments. For security, Allgreenivy does not collect or store sensitive cardholder data, such as full credit card numbers or card authentication data.	·         Performance of contract ·         Legal obligation ·         Legitimate interests (payment facilitation, fraud prevention and security, compliance)
Instructor Payment Data	If you are an instructor, you can link your PayPal, Payoneer, or other payment account to the Services to receive payments. When you link a payment account, we collect and use certain information, including your payment account email address, account ID, physical address, or other data necessary for us to send payments to your account. In some instances, we may collect ACH or wire information to send payments to your account. In order to comply with applicable laws, we also work with trusted third parties who collect tax information as legally required. This tax information may include residency information, tax identification numbers, biographical information, and other personal information necessary for taxation purposes. For security, Allgreenivy does not collect or store sensitive bank account information. The collection, use, and disclosure of your payment, billing, and taxation data is subject to the privacy policy and other terms of your payment account provider.	·         Performance of contract ·         Legal obligation ·         Legitimate interests (service provisioning, payment facilitation, fraud prevention and security, compliance)
Data About Your Accounts on Other Services	We may obtain certain information through your social media or other online accounts if they are connected to your Allgreenivy account. If you log in to Allgreenivy via Facebook or another third-party platform or service, we ask for your permission to access certain information about that other account. For example, depending on the platform or service we may collect your name, profile picture, account ID number, login email address, location, physical location of your access devices, gender, birthday, and list of friends or contacts. Those platforms and services make information available to us through their APIs. The information we receive depends on what information you (via your privacy settings) or the platform or service decide to give us. If you access or use our Services through a third-party platform or service, or click on any third-party links, the collection, use, and sharing of your data will also be subject to the privacy policies and other agreements of that third party.	·         Legitimate interests (identity verification, user experience improvement)
Sweepstakes, Promotions, and Surveys	We may invite you to complete a survey or participate in a promotion (like a contest, sweepstakes, or challenge), either through the Services or a third-party platform. If you participate, we will collect and store the data you provide as part of participating, such as your name, email address, postal address, date of birth, or phone number. That data is subject to this Privacy Policy unless otherwise stated in the official rules of the promotion or in another privacy policy. The data collected will be used to administer the promotion or survey, including for notifying winners and distributing rewards. To receive a reward, you may be required to allow us to post some of your information publicly (like on a winner’s page). Where we use a third-party platform to administer a survey or promotion, the third party’s privacy policy will apply.	·         Performance of contract ·         Legitimate interests (promotions administration, prize delivery, compliance)
Communications and Support	If you contact us for support or to report a problem or concern (regardless of whether you have created an account), we collect and store your contact information, messages, and other data about you like your name, email address, messages, location, Allgreenivy user ID, refund transaction IDs, and any other data you provide or that we collect through automated means (which we cover below). We use this data to respond to you and research your question or concern, in accordance with this Privacy Policy.	·         Legitimate interests (customer and technical support)

The data listed above is stored by us and associated with your account.

1.2 Data We Collect through Automated Means

When you access the Services (including browsing content), we collect certain data by automated means, including:

Category of Personal Data	Description	Legal Basis for Processing
System Data	Technical data about your computer or device, like your IP address, device type, operating system type and version, unique device identifiers, browser, browser language, domain and other systems data, and platform types.	·         Performance of contract ·         Legitimate interests (service provisioning, customer and technical support, fraud prevention and security, communication, product improvement)
Usage Data	Usage statistics about your interactions with the Services, including content accessed, time spent on pages or the Service, pages visited, features used, your search queries, click data, date and time, referrer, and other data regarding your use of the Services.	·         Legitimate interests (service provisioning, user experience improvement, product improvement)
Approximate Geographic Data	An approximate geographic location, including information like country, city, and geographic coordinates, calculated based on your IP address.	·         Legitimate interests (user experience improvement, fraud prevention and security, compliance)

The data listed above is collected through the use of server log files and tracking technologies, as detailed in the “Cookies and Data Collection Tools” section below. It is stored by us and associated with your account.

 

 

1.3 Data From Third Parties

If you are a Allgreenivy Business enterprise or corporate prospect, in addition to information you submit to us, we may collect certain business contact information from third-party commercial sources.

2. How We Get Data About You

We use tools like cookies, and similar tracking technologies to gather the data listed above. Some of these tools offer you the ability to opt out of data collection.

2.1 Cookies and Data Collection Tools

We use cookies, which are small text files stored by your browser, to collect, store, and share data about your activities across websites, including on Allgreenivy. They allow us to remember things about your visits to Allgreenivy, like your preferred language, and to make the site easier to use. To learn more about cookies, visit https://cookiepedia.co.uk/all-about-cookies. We may also use clear pixels in emails to track deliverability and open rates.

Allgreenivy and service providers acting on our behalf (like Google Analytics and third-party advertisers) use server log files and automated data collection tools like cookies, tags, scripts, customized links, device or browser fingerprints, and web beacons (together, “Data Collection Tools“) when you access and use the Services. These Data Collection Tools automatically track and collect certain System Data and Usage Data (as detailed in Section 1) when you use the Services. In some cases, we tie data gathered through those Data Collection Tools to other data that we collect as described in this Privacy Policy.

2.2 Why We Use Data Collection Tools

Allgreenivy uses the following types of Data Collection Tools for the purposes described:

 

 

• Strictly Necessary: These data collection tools allow you to access the site, provide basic functionality (like logging in or accessing content), secure the site, protect against fraudulent logins, and detect and prevent abuse or unauthorized use of your account. If you disable these tools, parts of the site may not work or be unavailable.
• Functional: These data collection tools remember data about your browser and preferences, provide additional site functionality, customize content to be more relevant to you, and remember settings affecting the appearance and behavior of the services (like your preferred language or volume level for video playback).
• Performance: These data collection tools help measure and improve the services by providing usage and performance data, visit counts, traffic sources, or where an application was downloaded from. These tools can help us test different versions of Allgreenivy to see which features or content users prefer and determine which email messages are opened.
• Advertising: These data collection tools are used to deliver relevant ads (on the site and/or other sites) based on things we know about you, like your usage and system data, and things that the ad service providers know about you based on their tracking data. The ads can be based on your recent activity or activity over time and across other sites and services. To help deliver tailored advertising, we may provide these service providers with a hashed, anonymized version of your email address (in a non-human-readable form) and content that you share publicly on the Services.
• Social Media: These data collection tools enable social media functionality, like sharing content with friends and networks. These cookies may track a user or device across other sites and build a profile of user interests for targeted advertising purposes. You have the option to set your web browser to alert you about attempts to place cookies on your computer, limit the types of cookies you allow, or refuse cookies altogether. If you do, you may not be able to use some or all features of the Services and your experience may be different or less functional. For more information on managing data collection tools, refer to Section 6.1 (Your Choices About the Use of Your Data) below.

Top of Form

3. What We Use Your Data For

We use your data to do things like provide our Services, communicate with you, troubleshoot issues, secure against fraud and abuse, improve and update our Services, analyze how people use our Services, serve personalized advertising, and as required by law or necessary for safety and integrity. We retain your data for as long as it is needed to serve the purposes for which it was collected.

We use the data we collect through your use of the Services to:

• • Provide and administer the Services, including to facilitate participation in educational content, issue completion certificates, display customized content, and facilitate communication with other users (Account Data; Shared Content; Learning Data; System Data; Usage Data; Approximate Geographic Data);
  • Process payments to instructors and other third parties (Student Payment Data; Instructor Payment Data);
  • Process your requests and orders for educational content, products, specific services, information, or features (Account Data; Learning Data; Student Payment Data; System Data; Communications and Support);
  • Communicate with you about your account by (Account Data; Shared Content; Learning Data; Sweepstakes, Promotions, and Surveys; System Data; Communications and Support):
    • Responding to your questions and concerns;
    • Sending you administrative messages and information, including messages from instructors, students, and teaching assistants; notifications about changes to our Service; and updates to our agreements;
    • Sending you information, such as by email or text messages, about your progress in courses and related content, rewards programs, new services, new features, promotions, newsletters, and other available instructor-created content (which you can opt out of at any time);

• Manage your account and account preferences, and personalize your experience. This includes using your account data, learning data, student payment data, instructor payment data, system data, usage data, and cookie data.
• Facilitate the technical functioning of the Services, including troubleshooting and resolving issues, securing the Services, and preventing fraud and abuse. This includes using your account data, student payment data, instructor payment data, communications and support, system data, and approximate geographic location data.
• Verify the identity of instructors. This includes using your account data and instructor payment data.
• Solicit feedback from users. This includes using your account data and communications and support data.
• Market products, services, surveys, and promotions. This includes using your account data, learning data, sweepstakes, promotions, and surveys data, usage data, and cookie data.
• Market subscription plans to prospective customers. This includes using your account data, learning data, and cookie data.
• Learn more about you by linking your data with additional data through third-party data providers and/or analyzing the data with the help of analytics service providers. This includes using your account data, data about your accounts on other services, usage data, and cookie data.
• Identify unique users across devices. This includes using your account data, system data, and cookie data.
• Tailor advertisements across devices. This includes using cookie data.
• Improve our Services and develop new products, services, and features. This includes using all data categories.
• Analyze trends and traffic, track purchases, and track usage data. This includes using your account data, learning data, student payment data, communications and support data, system data, usage data, approximate geographic data, and cookie data.
• Advertise the Services on third-party websites and applications. This includes using your account data and cookie data.
• As required or permitted by law. This includes using all data categories.
• As we determine to be necessary to ensure the safety or integrity of our users, employees, third parties, the public, or our Services. This includes using all data categories.

 

4. Who We Share Your Data With

We may disclose certain information about you to instructors, other students, service providers, affiliates, business partners, analytics and data enrichment providers, social media providers, companies assisting with promotions and surveys, and advertising companies to promote our services. We may also share your data for security purposes, to comply with legal requirements, or as part of a corporate reorganization. In addition, we may share your data in a aggregated or de-identified form or with your consent.

 

We may share your data with third parties under the following circumstances or as otherwise described in this Privacy Policy:

1. Allgreenivy shares certain data, such as your country, device settings, and course review activities, with instructors or teaching assistants to improve their content for you and other students. Your email address will not be shared.
2. Depending on your settings, other students and instructors may be able to view your shared content and profile data. If you ask a question to an instructor, your information may also be publicly viewable. It’s important to note that any chat rooms, message boards, or public forums available to participants on CorpU Open are publicly visible to other participants, so you should not post any confidential or proprietary information through these features.
3. Allgreenivy shares your data with third-party companies who provide services on our behalf, such as payment processing, data analysis, and customer support. These service providers are required to use your data solely as directed by Allgreenivy to provide the requested service.
4. Allgreenivy may share your data within our corporate family of companies that are related by common ownership or control to support the provision of the Services.
5. Allgreenivy has agreements with other websites and platforms to distribute our Services and drive traffic to Allgreenivy. Depending on your location, we may share your data with these partners.
6. If you take a course to fulfill a continuing professional education requirement, Allgreenivy may share that information with the organization granting the continuing education credit upon request.
7. Allgreenivy shares certain contact information or de-identified data with third-party analytics tools and data enrichment services to provide analytics services or match your data with publicly-available database information. This allows us to communicate with you in a more effective and customized manner.
8. Social media features in the Services, such as the Facebook Like button, may collect your IP address and page visit information, and set a cookie to enable the feature. These interactions are governed by the third-party company’s privacy policy.

Top of Form

• Allgreenivy may share your data as necessary to administer, market, or sponsor promotions and surveys you choose to participate in, as required by law, or in accordance with the rules of the promotion or survey.
• If Allgreenivy decides to use an advertising-supported revenue model in the future, we may use and share certain System Data and Usage Data with third-party advertisers and networks to show general demographic and preference information among our users. We may also allow advertisers to collect System Data through Data Collection Tools to personalize your user experience through targeted advertising and to undertake web analytics. Advertisers may also share data they collect about you with Allgreenivy. You can opt out of participating ad networks’ behavioral advertising by following the instructions in Section 6.1 of the privacy policy. Note that if you opt out, you will still be served generic ads.

• • For Security and Legal Compliance: We may disclose your data (all data categories) to third parties if we (in our sole discretion) have a good faith belief that the disclosure is:
    • Requested as part of a judicial, governmental, or legal inquiry, order, or proceeding;
    • Reasonably necessary as part of a valid subpoena, warrant, or other legally-valid request;
    • Reasonably necessary to enforce our Terms of Use, Privacy Policy, and other legal agreements;
    • Required to detect, prevent, or address fraud, abuse, misuse, potential violations of law (or rule or regulation), or security or technical issues;
    • Reasonably necessary in our discretion to protect against imminent harm to the rights, property, or safety of Allgreenivy, our users, employees, members of the public, or our Services;
    • We may also disclose data about you to our auditors and legal advisors in order to assess our disclosure obligations and rights under this Privacy Policy; or
    • Required or permitted by law.

• During a Change in Control: If Allgreenivy undergoes a business transaction such as a merger, acquisition, corporate divestiture, or dissolution, or a sale of assets, we may share, disclose, or transfer all of your data to the successor organization during the transition or in contemplation of the transition, including during due diligence.
• Allgreenivy may disclose or use aggregated or de-identified data for any purpose.
• With your permission, Allgreenivy may share your data with third parties outside the scope of this Privacy Policy.

 

5. Security

We use appropriate security based on the type and sensitivity of data being stored. As with any internet-enabled system, there is always a risk of unauthorized access, so it’s important to protect your password and to contact us if you suspect any unauthorized access to your account.

Allgreenivy takes appropriate security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal data that we collect and store. These measures vary based on the type and sensitivity of the data. Unfortunately, however, no system can be 100% secured, so we cannot guarantee that communications between you and Allgreenivy, the Services, or any information provided to us in connection with the data we collect through the Services will be free from unauthorized access by third parties. Your password is an important part of our security system, and it is your responsibility to protect it. You should not share your password with any third party, and if you believe your password or account has been compromised, you should change it immediately and contact our Support Team with any concerns.

6. Your Rights

You have certain rights around the use of your data, including the ability to opt out of promotional emails, cookies, and collection of your data by certain third parties. You can update or terminate your account from within our Services, and can also contact us for individual rights requests about your personal data. Parents who believe we’ve unintentionally collected personal data about their underage child should contact us for help deleting that information.

6.1 Your Choices About the Use of Your Data

You can choose not to provide certain data to us, but you may not be able to use certain features of the Services.

• To stop receiving promotional communications from us, you can opt out by using the unsubscribe mechanism in the promotional communication you receive or by changing the email preferences in your account. Note that regardless of your email preference settings, we will send you transactional and relationship messages regarding the Services, including administrative confirmations, order confirmations, important updates about the Services, and notices about our policies.
• The browser or device you use may allow you to control cookies and other types of local data storage. To learn more about managing cookies, visit https://cookiepedia.co.uk/how-to-manage-cookies. Your wireless device may also allow you to control whether location or other data is collected and shared.
• To get information and control cookies used for tailored advertising from participating companies, see the consumer opt-out pages for the Network Advertising Initiative and Digital Advertising Alliance, or if you’re located in the European Economic Area, visit the Your Online Choices site. If you’re located in Japan, visit the Digital Advertising Consortium. To opt out of Google’s display advertising or customize Google Display Network ads, visit the Google Ads Settings page. To opt out of Taboola’s targeted ads, see the Opt-out Link in their Cookie Policy.
• To opt out of allowing Google Analytics, Mixpanel, ZoomInfo, or Clearbit to use your data for analytics or enrichment, see the Google Analytics Opt-out Browser Add-on, Mixpanel Opt-Out Cookie, ZoomInfo’s policy, and Clearbit data claiming mechanism.

If you have any questions about your data, our use of it, or your rights, contact us at privacy@Allgreenivy.com. 

6.2 Accessing, Updating, and Deleting Your Personal Data

You can access and update your personal data that Allgreenivy collects and maintains as follows:

• To update data you provide directly, log into your account and update your account at any time.
• To terminate your account:
  • If you are a student, visit your profile settings page and follow the steps detailed here.
  • If you are an instructor, follow the steps detailed here .
  • If you have any issues terminating your account, please contact our Support Team. 
  • Please note: even after your account is terminated, some or all of your data may still be visible to others, including without limitation any data that has been (a) copied, stored, or disseminated by other users (including comments on content); (b) shared or disseminated by you or others (including in your shared content); or (c) posted to a third-party platform. Even after your account is terminated, we retain your data for as long as we have a legitimate purpose to do so (and in accordance with applicable law), including to assist with legal obligations, resolve disputes, and enforce our agreements. We may retain and disclose such data pursuant to this Privacy Policy after your account has been terminated.
• To request to access, correct, or delete your personal data, please use our online form here.  You can also submit these requests by emailing privacy@allgreenivy.com. Please allow up to 30 days for a response. For your protection, we may require that the request be sent through the email address associated with your account, and we may need to verify your identity before implementing your request. Please note that we retain certain data where we have a lawful basis to do so, including for mandatory record-keeping and to complete transactions.

6.3 Our Policy Concerning Children

We recognize the privacy interests of children and encourage parents and guardians to take an active role in their children’s online activities and interests. Individuals younger than 18 years of age, but of the required age for consent to use online services where they live, may not set up an account, but may have a parent or guardian open an account and help them access appropriate content. Individuals younger than the required age for consent to use online services may not use the Services. If we learn that we’ve collected personal data from a child under those ages, we will take reasonable steps to delete it.

Parents who believe that Allgreenivy may have collected personal data from a child

under those ages can submit a request that it be removed to privacy@allgreenivy.com

7. Updates & Contact Info

When we make a material change to this policy, we’ll notify users via email, in-product notice, or another mechanism required by law. Changes become effective the day they’re posted. Please contact us via email or postal mail with any questions, concerns, or disputes.

7.1 Modifications to This Privacy Policy

Allgreenivy may update the Privacy Policy from time to time. If there are any significant changes to the policy, we will notify you via email, through a notification on the Services, or as required by law. We will also provide a summary of the key changes. Unless stated otherwise, these modifications will take effect on the day they are posted. By continuing to use the Services after the effective date of any changes to the policy, you are indicating your acceptance of and agreement to follow and be bound by the revised Privacy Policy. The revised Privacy Policy supersedes all previous versions of the policy.

7.2 Interpretation

Any capitalized terms not defined in this policy are defined as specified in Allgreenivy’s Terms of Use. Any version of this Privacy Policy in a language other than English is provided for convenience. If there is any conflict with a non-English version, you agree that the English language version will control.

7.3 Questions

If you have any questions, concerns, or disputes regarding our Privacy Policy, please feel free to contact our privacy team (including our Data Protection Officer) at privacy@allgreenivy.com.