Effective Date: March 16, 2018
What personally identifiable information is collected from you through the Site, how it is used and with whom it may be shared.
What choices are available to you regarding the use of your information.
The security procedures in place to protect the misuse of your information.
How you can correct any inaccuracies in your data.
Information Collection and Use
Our Site has the ability to collect two types of information from and about you: (i) personally identifiable information; and (ii) non-personally identifiable information, both as defined below. We are the sole owners of the information collected on our Site. We only have access to or collect information from you (i) in connection with your use of the Site; and (ii) that you voluntarily give us via email or other direct contact from you.
Personally Identifiable Information
Our definition of personally identifiable information includes any information that may be used to specifically identify or contact you, such as your name, postal and email addresses, phone number or bank, debit or credit card information. In certain circumstances, we may request, allow or otherwise provide you an opportunity to submit your personally identifiable information in connection with a feature, program, promotion, sale or some other aspect of our Site. For instance, you may (i) voluntarily provide your name, address, phone number and email address to register an account with us or register to try our products or services; (ii) provide certain demographic information about yourself (e.g., age, gender, purchase preference, usage frequency, etc.) when participating in a survey or poll, or registering or creating a profile through any portion of our Site; (iii) provide payment information when providing payment via our Site; or (iv) post or send a general comment or recommendation on our Site or other Site. Certain information may not be personally identifiable when standing alone (e.g., your age), but may become so when combined with other information (e.g., your age and name). Whether or not you provide this information is your choice; however, in many instances this type of information is required to participate in the particular activity or service, realize a benefit we may offer or gain access to certain content through our Site. For instance:
We may use your personal identifiable information to fulfill your requests for our products and services;
If you sign up to receive updates from us by submitting your name and email address on our Site, we may use this information to send you updates on our products and services;
If you send us an email or use an online form to contact us with questions or comments, we may use your personally identifiable information to respond to your questions or comments, and we may save your questions or comments for future reference. For security reasons, we do not recommend that you send non-public personal identifiable information, such as passwords, credit card information, social security numbers or bank account information, to us by email. In certain instances, we may provide you with the option to set your preferences for receiving email communications from us; that is, agree to some communications, but not others. We reserve the right to send you transactional emails such as customer service communications or receipts;
Unless you ask us not to, we may use your personal identifiable information to contact you in the future to tell you about specials, new products or services, or to communicate with you about content or other information you have posted or shared with us via our Site.
We may use your personal identifiable information to personalize your online experience and in other ways naturally associated with the circumstances in which you provided the information.
Our definition of Non-personal Information is any information that does not personally identify you. Non-personal Information can include certain personally identifiable information that has been de-identified; that is, information that has been rendered anonymous. We obtain Non-personal Information about you from information that you provide us, either separately or together with your personally identifiable information. We also automatically collect certain Non-personal Information from you when you access our Site. This information can include, among other things: your IP address or other unique identifiers that are automatically assigned to your computer, mobile or other device used to access the Site; the type of browser you are using (e.g., Internet Explorer, Firefox, Safari, etc.); the third party website from which your visit originated; the operating system you are using (e.g., Vista, Windows XP, Mac OS, etc.); the domain name of your Internet service provider; the search terms you use on our Site; the specific areas within our Site that you visit; and the time of day and duration of your visits.
We may use any Non-personal Information for any purposes as appropriate and subject to applicable law, since Non-personal Information cannot identify you as an individual. These purposes can include: to administer the Site, help us analyze site traffic, understand customer needs and trends, marketing activities, and to improve the quality of the pages or functionality that make up our Site or otherwise to improve our Site or your experience on the Site. We may use your Non-personal Information by itself or aggregate it with information we have obtained from others. We may share your Non-personal Information with our affiliated companies to create summary statistics that help us analyze Site usage trends, assess what information is of most and least importance, determine technical design specifications, arrange the Sites in a user-friendly way, and identify system performance or problem areas.
In addition to the foregoing, we may use your personally identifiable information or Non-personal Information as follows:
When required by law or court order;
To provide you with information or services or process transactions that you have requested or agreed to receive, including to send you electronic newsletters, to facilitate a purchase, or to provide you with special offers or promotional materials from us;
To improve the Site, to customize your experience with the Site or to serve you specific content that we believe is relevant to you;
To enable you to participate in a variety of the Site’s features;
To contact you with regard to your use of the Site and, in our discretion, changes to the Site and related policies;
For inclusion in our data analytics;
To protect or defend our legal rights or property, our Site or other users; and
During an emergency to protect the health and safety of our users or the general public.
When We Share Your Personal Identifiable Information
When you submit information to us through any of our Site, you should be aware that your information is transmitted across the internet and that no method of transmission over the internet is completely or 100% secure. While we take reasonable precautions to protect your information, you also need to ensure you take appropriate steps to protect your information. We have implemented security measures we consider reasonable and appropriate to protect against the loss, misuse and alteration of the information under our control. Please be advised, however, that while we strive to protect your personally identifiable information, other information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online, and we are not responsible for the theft, destruction or inadvertent disclosure of your personally identifiable information or any other information. In the unfortunate event that your personally identifiable information (as the term or similar terms are defined by any applicable law requiring notice upon a security breach) is compromised, we may notify you by e-mail (at our sole and absolute discretion and according to applicable law), to the last email address you have provided us, in the most expedient time reasonable under the circumstances; provided, however, delays in notification may occur while we take necessary measures to determine the scope of the breach and restore reasonable integrity to the system as well as for the legitimate needs of law enforcement if notification would impede a criminal investigation. From time to time, we evaluate new services for protecting information and, when appropriate, we upgrade our information security systems.
Information Collection Methods
A few of the methods and/or avenues that may be used to collect Non-personal information include, without limitation, the following (as well as subsequent Site and methods later developed):
We use “cookies” on our Site. A cookie is a piece of data stored on a user’s hard drive to help us improve your access to our Site and identify repeat visitors to our Site. For instance, when we use a cookie to identify you, you may not have to log in using a password more than once, thereby saving time while on our Site. Cookies can also enable us to track and target the interests of our users to enhance the experience on our Site. Usage of a cookie is in no way linked to any personally identifiable information on our Site.
“Web beacons” are small graphic images or other web programming code that may be included in our Site pages or other areas of the Site. Web beacons are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of users of our Site pages and Site. Unlike cookies, which are typically stored on your computer or mobile device’s hard drive, web beacons are embedded invisibly on web pages. Web beacons or similar technologies help us better manage content on our Site and other services by informing us what content is effective, counting the number of users of the Site and other Site, monitoring how users navigate the Site and other Site or counting how many e-mails, articles or links were actually opened or viewed.
An “embedded script” is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your computer, mobile or other device from our server or a third party service provider.
Web Traffic and Web Performance Analytics
An IP address is a number that is assigned to your computer, mobile or other computing device whenever you are surfing the Internet. Web servers (computers that “serve up” web pages) automatically identify your computer or other computing device by its IP address. When users request pages from our Site, our servers may log their IP addresses. We may collect IP addresses for the following purposes, among others: system administration, to report non-personal aggregate information to others and to track the use of our Site. IP addresses are considered Non-personal information and may also be shared as provided above.
Children & Education
This section describes how Vital handles children’s information. We understand the importance of taking extra precautions to protect the privacy and safety of children using our Site. Children under the age of 13, or equivalent minimum age in the relevant jurisdiction, are not permitted to create their own accounts for our services, unless their parent provided verifiable consent or as part of the child account creation process or they have obtained an account (where available) through their school.
If we learn that we have collected the personal identifiable information of a child under 13, or equivalent minimum age depending on jurisdiction, outside the above circumstances we will take steps to delete the information as soon as possible. If at any time a parent needs to access, correct, or delete data associated with their children’s account, they may contact us via email at firstname.lastname@example.org.
Your Privacy Choices
We strive to maintain the accuracy of any personal identifiable information that may be collected from you, and will use our commercially reasonable efforts to respond promptly to update our database when you tell us any such information in our database is not accurate. It is your responsibility to ensure that such information is accurate, complete and up-to-date. You may opt out of any future contacts from us at any time. You can do the following at any time by contacting us via the email address or phone number given on our Site. You may obtain from us, by email or mail, the information in our records and/or files. If you wish to make any changes to any Personal identifiable information you have provided to us, you may do so at any time by contacting us at email@example.com.
California Civil Code Section 1798.83 permits users that are residents of California to request the following information regarding our disclosure of your personal identifiable information to third parties for those third parties’ direct marketing purposes: (i) a list of certain categories of personally identifiable information that we have disclosed to certain third parties for their direct marketing purposes during the immediately preceding calendar year; (ii) the identity of certain third parties that received personally identifiable information from us for their direct marketing purposes during that calendar year; and (iii) examples of the products or services marketed (if we have that information). If you are a California resident and would like to make such a request, please email us at firstname.lastname@example.org or write us at the address below:
JLG Innovations Inc.
911 Washington, Suite 501
St. Louis, MO 63101
Users from Outside the United States
Effective Date: March 16, 2018
A Message for Parents and School Personnel
The Children’s Online Privacy Protection Act (“COPPA”) requires us to inform parents and legal guardians about how we collect, use, and disclose personal information from children under the age of 13. It also requires that we obtain parental consent before we allow children under the age of 13 to use certain features of the Mobile App.
“Parent” includes legal guardians.
“Child” means a child that is under the age of 13.
“Personal Information” means individually identifiable information about an individual that is collected online, such as first and last name, a home address, an e-mail address, a telephone number, or any information collected from an individual and combined with such identifying information.
This Policy will notify you of the following:
Our name, address, telephone number, and email address and how we collect or maintain personal information through the Mobile App;
A description of what information we collect from children, including whether we enable children to make their personal information publicly available, how we use such information, and our disclosure practices for such information; and
How you, as a parent, can review or have deleted the child’s personal information and refuse to permit its further collection or use, and state the procedures for doing so.
For more information about COPPA, click here.
1. Scope of this Policy
BY USING OR ACCESSING OUR MOBILE APP AND SERVICES, OR BY PERMITTING YOUR CHILD TO USE OR ACCESS OUR MOBILE APP AND SERVICES, YOU ARE ACCEPTING THE PRACTICES DESCRIBED IN THIS POLICY.
2. About Us
We operate our Mobile App, including any web pages and services associated with the Mobile App. We strive to safeguard the privacy of your children while they use our Mobile App.
The Mobile App allows students with different learning styles to interact with teachers and lesson plans, curriculum, and other learning aids (“teaching materials”) to, hopefully, allow each student to better understand the teaching materials. Teachers and other school personnel can access our service via the web to reformat and transform their teaching materials into a format that may be better suited for their respective students. The teachers can then “push” or send these teaching materials to their students via the Mobile App, in which students can log into the Mobile App to access and interact with the teaching materials. With the use of the Mobile App, students may also be able to interact with one another or with their teachers and other school personnel.
We generally provide services to schools and other educational institutions to improve student learning. As such, the Mobile App is directed to individuals who are, both: (a) 13 years of age or older, such as older students and teachers and other school personnel, and (b) children under the age of 13, such as younger students. However, we do not knowingly collect any information from children under the age of 13 unless and until a school or educational institution has provided appropriate consent and authorization for a student under 13 to use the Mobile App and for us to collect information from such student. In some cases, where we provide our services directly to individual teachers instead of through a school or other educational institution, we will not knowingly collect any information from children under the age of 13 unless and until we have “verifiable parental consent” for a student under 13 to use the Mobile App and for us to collect information from such student. In these cases, we require that all registrations to use the Mobile App that contain any information of any child under the age of 13 be accompanied by a verifiable parental consent.
Once we have been provided with the appropriate consent, either from the school or educational institution or the individual teachers, then a student under 13 can register to use the Mobile App (All such use must also adhere to the EULA).
Additionally, no user of our Mobile App or other services is permitted to upload content in public areas that contains the name, address, contact information (including online contact information), geolocation information, telephone number, Social Security number, image, voice, any persistent identifiers, or other “personal information” under COPPA concerning any individual under 13 years of age.
4. Information We Collect From Children and How We Collect It
Information We Collect Directly
Our Mobile App has the ability to collect two types of information from and about a student under 13: (i) personally identifiable information; and (ii) non-personally identifiable information. We directly collect information from a student under 13 (i) in connection with their use of the Mobile App; (ii) that they (or a teacher or other school personnel) voluntarily give to us when registering an account for that student on our Mobile App, and (iii) that they may send to us when they contact us directly.
Typically, only a child’s user name or email is publically available to other users of the Mobile App. This includes, for example, teachers who may be able to see information for a child (e.g., email address, first and last name, login status) that has enrolled in their class, courses, or that can otherwise receive that teacher’s content. In some cases, however, other personally identifiable information or non-personally identifiable information about a student under 13 could be made publically available if it is included in teaching materials or other user content posted by users of the site.
Information We Collect Passively
We may passively collect personal information of a child under the age of 13 if we are unaware that user content submitted with the teaching materials and other postings contains that information. We also may passively collect information on Mobile App usage patterns or through content that users post or access on our Mobile App or any services associated with the Mobile App. For example, we may collect certain information from all visitors to our Mobile App, such as device/IP address used to access and/or install the Mobile App, hardware version, device settings, device identifiers, the date and time of visit, language, time spent on the Mobile App, the type of operating system used (e.g., iOS), the ISP from which the visitor receives Internet access, and information regarding what pages and content users of the Mobile App access or visit.
Parents should advise their children not to share any personally identifiable or contact information online. Parents should closely monitor their children’s use of the Mobile App and their participation in any activities and services on the Mobile App.
5. Tracking Activities on the Mobile App
When a child is merely viewing the Mobile App, we track the pages visited and the length of time spent logged. This information is associated with any computer or device that accesses the Mobile App. Unless a user is logged in, however, we have no specific information that would indicate to us whether the viewer a child or an adult.
When a user is logged in to our Mobile App, we also track the pages/Content visited, the length of time spent on the pages/Content, and the interactions with the pages/Content. This includes, for example, that we collect certain usage and tracking data, such as finger tracking, gestures for using the Mobile App, and accessibility settings on the tablet or device on which the Mobile App is installed – all of which allows us to analyze traffic and usage trends, such as exploratory procedures of students with visual impairments, to improve our services and use of the Mobile App and Content, as well as to provide insights into teaching and learning methods and styles of users of the Mobile App.
We may partner with third parties to provide content and/or other services, such as Google Classroom. We will not share your child’s personally identifiable information with these third parties; however, you or your child may separately register with these third parties to access the content or other services. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users that leave our Mobile App to be aware of and to read the privacy statements of any other site, as we have no control over information that is submitted to, or collected by, these third parties. Also, please note that some of these third parties may use tracking technologies, such as cookies and Web beacons, on our Mobile App in order to track user activity. We do not exercise control over or have access to these tracking technologies or the information practices of these parties, which are subject to the privacy policies of these third parties.
6. How We Use Your Child’s Personal Information
We may use the personal information that we collect from a child to determine whether he or she is eligible to use our Mobile App, to provide our services to the child and their teacher or other school personnel, and to provide teaching materials and other content that we believe that the child may be interested in.
We may also use non-personal information such as information about the pages visited to improve the design, content and performance of our Mobile App and the experience on our Mobile App, or to analyze site usage and the popularity of certain pages of or content on the Mobile App.
Parents may request information from us on the type of data being collected, and, if they choose, prohibit us from making further use of their child’s information. For more information on how to do this, see the section below entitled “How To Review, Delete or Alter the Information Collected From Your Child.”
7. How We Share a Child’s Personal Information with Third Parties
We will not sell, rent or trade your child’s personal information. We may disclose the personal information we obtain from children to our affiliates or third party service providers that support our business, such as companies that provide technical infrastructure or support (like a content delivery network), provide customer service, or analyze how the Mobile App is being used to help us improve the services. We may also disclose such information to your child’s teacher or other school personnel and to our third party vendors who may generate content, process consents and requests made by the child on the Mobile App, and/or monitor or manage interactive features available on our Mobile App. We will take steps to assure that these affiliates or third parties have agreed to maintain the confidentiality, security and integrity of personal information, and the information is not shared with any of these third parties for their own marketing purposes.
Aggregate and Anonymized Information
We may also share aggregate or anonymized information about children with non-affiliated third parties for advertising, marketing or research purposes. For example, we may share demographic information about users with our marketing partners and third party advertisers, which may be used to determine what advertising, marketing or research content to display to actual or potential users of the Mobile App (whether outside or within the Mobile App). However, we will never knowingly share your child’s personally identifiable information with any third parties for marketing, advertising or research purposes and we do not knowingly serve targeted advertisements within our Mobile App to children.
We may also use and share raw or aggregated and/or anonymized information about our users, including usage and tracking data from children, for other research purposes, such as to develop new products and services, to improve our current products and services, and in connection with understanding and exploring learning behaviors and other trends of our users, such as using finger tracking data for exploratory procedures of students with visual impairments.
8. How To Review, Delete or Alter the Information Collected From Your Child
You can review your child’s personal information that we have collected at any time by contacting us at the below address. You may revoke consent for us to collect your child’s personal information at any time. You can also have your child’s personal information deleted and refuse to permit further collection of such information by us. However, please understand that, even after removal, some content may remain viewable in cached and archived pages or by others if a member has copied or stored such content. Furthermore, please understand that if you revoke your consent or ask that your child’s information be deleted, then your child may no longer have access to the Mobile App or the services that we provide.
If you wish to view, delete or modify the information we have collected about your child, you may do this by contacting us at:
JLG Innovations Inc.
911 Washington Avenue
St. Louis, MO 63101
9. Data Security
We have implemented commercially reasonable safeguards to protect personal information that we collect and store. Despite these precautions, however, no data security safeguards are foolproof. Unauthorized individuals may find ways to obtain personal information from or to access the Mobile App. Please keep in mind that we cannot and do not guarantee that content posted at the Mobile App will not be viewed by unauthorized persons. Any content that you post or allow your child to post is at your own risk.
10. Third Party Links
At times, our Mobile App contains links to other, third party sites that we do not control or maintain. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users that leave our Mobile App to be aware of and to read the privacy statements of any other site, as we have no control over information that is submitted to, or collected by, these third parties. We cannot and will not be responsible for the protection and privacy of any information that you or your child provide while visiting such websites and such websites are not governed by any of our privacy policies or practices.
12. Contact Us
If you have questions, comments or concerns about any of our privacy policies or practices, or to raise any other issue related to privacy, you may contact us at:
JLG Innovations Inc.
911 Washington Avenue
St. Louis, MO 63101