Privacy Policy

Last updated: September 1, 2020

AganaMed Privacy Principles

Our Privacy Policy is based on our commitment to the following Privacy Principles:

  1. We’re deeply committed to creating a safe and secure online environment for you
  2. We do not sell your personal information to third parties
  3. We strive to provide you with access to and control over the information you give us and we take the protection of your information very seriously
  4. We do not display advertising on our website

Key Information

  • AganaMed LLC is the data controller of your personal information.
  • We collect the personal information set out in the “What Information We Collect” section of this Privacy Policy below, including account signup details such as name and email, course feedback and other form information (where you provide it), and information about your use of our site and Services.
  • We use your personal information for the purposes set out in the “How We Use the Information” section of this Privacy Policy below, including providing our site and Services to you, ensuring the security and performance of our site, conducting research relating to Content Offerings, sharing information with our Content Providers and our suppliers, direct marketing, and performing statistical analysis of the use of our site and Services.
  • You have a number of rights that you can exercise in relation to our use of your personal information, as set out in the “Updating or Deleting Your Personally Identifiable Information” section of this Privacy Policy below.

Contents

You can find information about us and how we collect, use and store your personal data in the following sections of this Privacy Policy:

  1. Purpose and Who We Are
  2. What Information this Privacy Policy Covers
  3. What You Agree to by Using Our Site
  4. What Information We Collect
  5. How We Use the Information
  6. External Links
  7. Retention of Personally Identifiable Information
  8. Confidentiality & Security of Personally Identifiable Information
  9. Updating or Deleting Your Personally Identifiable Information
  10. Cookies Policy
  11. International Privacy Practices
  12. European Union Data Protection
  13. Changing Our Privacy Policy
  14. No Information from Children Under 13
  15. Contacting AganaMed
  16. Revisions

1. Purpose and Who We Are

The purpose of this Privacy Policy is to describe how  AganaMed LLC (“AganaMed,” “us,” “we,” or “our”) collects, uses, and shares information about you through our online interfaces (e.g., websites and mobile applications) owned and controlled by us, including but not limited to aganamed.com (referred to herein as the “Site”).  Please read this Privacy Policy carefully to understand what we do. If you do not understand any aspects of our Privacy Policy, please feel free to contact us via the “Contacting AganaMed” section of this Privacy Policy below.

Your use of our Site is also governed by our Terms of Use.  Terms used but not defined in this Privacy Policy can be found in our Terms of Use.  AganaMed LLC is a California Limited Liability Company with the business mailing address listed in the “Contacting AganaMed” section of this Privacy Policy below.  If you reside or are located in the European Economic Area (“EEA”), AganaMed is the data controller of all Personally Identifiable Information (as defined below) collected via the Site and of certain Personally Identifiable Information collected from third parties, as set out in this Privacy Policy.

2. What Information this Privacy Policy Covers

This Privacy Policy covers information we collect from you through our Site.  Many of our Site’s functionality can be used without revealing any Personally Identifiable Information, though for features or Services related to some Content Offerings, Personally Identifiable Information is required.  In order to access certain features and benefits on our Site, you may need to submit, or we may collect,

“Personally Identifiable Information” (i.e., information that can be used to identify you)(may also be referred to as “personal data” or “personal information”).  Personally Identifiable Information can include information such as your name, email address, IP address, and device identifier, among other things. You are responsible for ensuring the accuracy of the Personally Identifiable Information you submit to AganaMed. Inaccurate information may affect your ability to use the Site, the information you receive when using the Site, and our ability to contact you. For example, your email address should be kept current because that is one of the primary manners in which we communicate with you.

3. What You Agree to by Using Our Site

We consider that the legal bases for using your personal information as set out in this Privacy Policy are as follows:

  • Our use of your personal information is necessary to perform our obligations under any contract with you (for example, to comply with the Terms of Use of our Site which you accept by browsing our website and/or to comply with our contract to provide Services to you); or
  • Our use of your personal information is necessary for complying with our legal obligations; or
  • Use of your personal information is necessary for our legitimate interests or the legitimate interests of others. Our legitimate interests are to:
    • run, grow and develop our business,
    • operate our Site and provide our Services,
    • select appropriately skilled and qualified suppliers,
    • build relationships with partners and academic institutions,
    • carry out research and statistical analysis,
    • carry out marketing and business development, and
    • for internal administrative and auditing purposes.
  • Consent, to send you certain communications or where you submit certain information to us.

Which legal basis applies to a specific processing activity will depend on the type of personal information processed and the context in which it is processed.

If we rely on our (or another person’s) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person’s) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information.

We may process your personal information in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time as described below).

If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by visiting your profile page and clicking the box to remove applicable consent and/or by contacting us via the “Contacting AganaMed” section of this Privacy Policy below and we will stop doing so accordingly.  However, if you withdraw your consent, this may impact the ability for us to be able to provide our Services to you.

4. What Information We Collect

We gather two types of information about users through the Site:

  1. Information relating to your use of our Site. When users come to our Site, we may track, collect, and aggregate information indicating, among other things, which pages of our Site were visited, the order in which they were visited, when they were visited, and which hyperlinks were clicked. We also collect information from the URLs from which you linked to our Site. Collecting such information may involve logging the IP address, operating system and browser software used by each user of the Site. We may be able to determine from an IP address a user’s Internet Service Provider and the approximate geographic location of his or her point of connectivity. We also use (or may use) cookies and web beacons when you visit our Site. For more information on our use of cookies and web beacons, please refer to the “Cookies Policy” section of this Privacy Policy below.
  2. Personally Identifiable Information provided directly by you or via third parties. We collect Personally Identifiable Information that you provide to us when you register for an account, update or change information for your account, purchase products or Services, complete a form, sign-up for email updates, participate in our public forums, send us email messages, and/or participate in Content Offerings or other Services on our Site. We may use the Personally Identifiable Information that you provide to respond to your questions, provide you the specific Content Offering and/or Services you select, send you updates about Content Offerings or other AganaMed events, and send you email messages about Site maintenance or updates.
  • Account Registration. If you register for an account on our Site, you may be required to provide us with Personally Identifiable Information such as your name and email address.
  • Updates. AganaMed may offer you the ability to receive updates either via email or by posting on portions of the Site only accessible to registered users. In order to subscribe to these Services, you may be required to provide us with Personally Identifiable Information such as your name and email address.
  • Forums. AganaMed may offer public forums from time to time (the “Forums”) where you can share comments and thoughts. In order to participate in the Forums, you may be required to register with us and/or provide us with Personally Identifiable Information such as your name and email address. Please keep in mind that information you post or make available in Forums will be publicly available. You should not include any Personally Identifiable Information or other information of a personal or sensitive nature, whether relating to you or another person, in a Forum post. Please also reference our Terms of Use and additional information about proper use of our Forums.
  • Participation in Content Offerings. AganaMed offers users the opportunity to participate in an Content Offerings on or through the Site. If you desire to participate in a Content Offering, you will be asked to provide us with certain information necessary to conduct such a Content Offering. This information may include, among other things, your name and email address.

If you participate in a Content Offering, we may collect from you certain student-generated content, such as assignments you submit to instructors, peer-graded assignments, and peer grading student feedback. We also collect course data, such as student responses to in-video quizzes, stand-alone quizzes, exams, forms, and surveys. You should not include any Personally Identifiable Information or other information of a personal or sensitive nature, whether relating to you or another person, on assignments, quizzes, exams, forms, or surveys, except for information required to participate or submit such assignments, quizzes, exams, forms, or surveys.

  • Communications with AganaMed. We may receive Personally Identifiable Information when you send us an email message or otherwise contact us.
  • Third Party Sites. We may receive Personally Identifiable Information when you access or log-in to a third party site, e.g., Google or Facebook, from our Sites. This may include the text and/or images of your Personally Identifiable Information available from the third party site.
  • Forms and Surveys. We may receive Personally Identifiable Information when you provide information in response to a form or survey operated by us or a Content Provider.
  • Partner sites. Partner sites providing Content Offering related tools and services to AganaMed users may collect nonfinancial individual-level user data regarding the individual’s use of that partner site while the partner sites provide those services to AganaMed. The partner sites may share that data with AganaMed for the purpose of improving AganaMed’s Services, the partner site’s services, and the individual’s education experience. This data includes information such as the amount of time spent on the partner site and pages viewed.
  • Third Party Credit Card and Debit Card Processing. AganaMed provides you with the ability to pay for Content Offerings and other Services using a credit card or debit card through a third party payment processing service provider. Please note that our payment service provider – not AganaMed – collects and processes your credit card and/or debit card information.

5. How We Use the Information

  1. Information relating to your use of our Site. We use information relating to your use of the Site to build higher quality, more useful Services by performing statistical analyses of the collective characteristics and behavior of our users, and by measuring demographics and interests regarding specific areas of our Site. We may also use this information to ensure the security of our Services and the Site.  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 Sites and to understand more about the demographics of our users.
  2. Personally Identifiable Information provided directly by you or via third parties. Except as set forth in this Privacy Policy or as specifically agreed to by you, AganaMed will not disclose any of your Personally Identifiable Information. In addition to the other uses set forth in this Privacy Policy, we may disclose and otherwise use Personally Identifiable Information as described below:
  • Providing the Site and our Services. We use Personally Identifiable Information which you provide to us in order to allow you to access and use the Site and in order to provide any information, products, or Services that you request from us.
  • Technical support and security. We may use Personally Identifiable Information to provide technical support to you, where required, and to ensure the security of our Services and the Site.
  • Updates. We use Personally Identifiable Information collected when you sign-up for our various email or update services to send you the messages in connection with the Site or Content Offerings. We may also archive this information and/or use it for future communications with you, where we are legally entitled to do so.
  • Forums. You should not post any Personally Identifiable Information or other information of a personal or sensitive nature, whether relating to you or another person, within a Forum post. If you choose to post Personally Identifiable Information, such Personally Identifiable Information may be collected during your use of the Forums. We may publish this information via extensions of our Platform that use third-party services, like mobile applications. We reserve the right to reuse Forum posts that contain Personally Identifiable Information in future versions of the Content Offerings, and to enhance future Content Offerings. We may archive this information and/or use it for future communications with you and/or your designee(s), and/or provide it to the Content Provider, business partner, or the instructor(s) associated with the courses you have taken. We may also use or publish posts submitted on the Forums without using Personally Identification Information.
  • Participation in Content Offerings. We use the Personally Identifiable Information that we collect from you when you participate in a Content Offering through the Site for processing purposes, including but not limited to tracking attendance, progress, and completion of the Content Offerings. We may also share your Personally Identifiable Information and your performance in a given Content Offering with the instructor or instructors who taught it, with teaching assistants or other individuals designated by the instructor or instructors to assist with the creation, modification, or operation of the Content Offering, and with the Content Provider(s) with which they are affiliated. We may also use the information generated when taking a Content Offering or using the Services for predictive analysis of your performance in the Content Offerings. Also, we may archive this information and/or use it for future communications with you, where we are legally entitled to do so.
  • Identity Verification. For Services that require identity verification, we may use the Personally Identifiable Information that we collect for verifying your identity, and for authenticating that submissions made on the Site were made by you. This Service may be provided through a third-party identity verification vendor. Your photo identification document will be deleted after successful verification of your profile information.
  • Communications with or from AganaMed. When you send us an email message or otherwise contact us, we may use the information provided by you to respond to your communication and/or as described in this Privacy Policy. We may also archive this information and/or use it for future communications with you where we are legally entitled to do so. Where we send you emails, we may track the way that you interact with these emails (such as when you open an email or click on a link inside an email). We use this information for the purposes of optimizing and better tailoring our communications to you.
  • Research. We may share general course data (including quiz or assignment submissions, grades, and forum discussions), information about your activity on our Site, and demographic data from surveys operated by us with our Content Providers and other business partners so that our Content Providers and other business partners may use the data for research related to online education.
  • Disclosure to AganaMed Operations and Maintenance Contractors. We use various service providers, vendors and contractors (collectively, “Contractors”) to assist us in providing our Services to you. Our Contractors may have limited access to your Personally Identifiable Information in the course of providing their products or services to us, so that we in turn can provide our Services to you. These Contractors may include vendors and suppliers that provide us with technology, services, and/or content related to the operation and maintenance of the Site or the Content Offerings. Access to your Personally Identifiable Information by these Contractors is limited to the information reasonably necessary for the Contractor to perform its limited function for us.
  • Government Authorities, Legal Rights and Actions. AganaMed may share your Personally Identifiable Information with various government authorities in response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights or to protect our property; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us. We also may share your Personally Identifiable Information when we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of AganaMed, the Site, our users, customers, or others; and in connection with our Terms of Use and other agreements.
  • Disclosure to Acquirers. AganaMed may disclose and/or transfer your Personally Identifiable Information to an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of the equity, business, or assets of AganaMed to which your Personally Identifiable Information relates.
  • e-Readers. If we receive any Personally Identifiable Information related to the extent to which you use designated e-Readers to access AganaMed materials, we may archive it, and use it for research, business, or other purposes.

6. External Links

For your convenience, we may provide links to sites operated by organizations other than AganaMed (“Third Party Sites”) that we believe may be of interest to you. We do not disclose your Personally Identifiable Information to these Third Party Sites unless we have a lawful basis on which to do so. We do not endorse and are not responsible for the privacy practices of these Third Party Sites. If you choose to click on a link to one of these Third Party Sites, you should review the privacy policy posted on the other site to understand how that Third Party Site collects and uses your Personally Identifiable Information.

7. Retention of Personally Identifiable Information

We keep your Personally Identifiable Information for no longer than necessary for the purposes for which the Personally Identifiable Information is collected and processed. The length of time we retain Personally Identifiable Information for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise, or defend our legal rights.

8. Confidentiality & Security of Personally Identifiable Information

We consider the confidentiality and security of your information to be of the utmost importance. We will use industry standard physical, technical, and administrative security measures to keep your Personally Identifiable Information confidential and secure, and will not share it with third parties, except as otherwise provided in this Privacy Policy, or unless such disclosure is necessary in special cases, such as a physical threat to you or others, as permitted by applicable law. Because the Internet is not a 100% secure environment, we cannot guarantee the security of Personally Identifiable Information, and there is some risk that an unauthorized third party may find a way to circumvent our security systems or that transmission of your information over the Internet will be intercepted. It is your responsibility to protect the security of your login information, for example, by choosing a strong password and keeping it confidential.  Please note that e-mail communications are typically not encrypted and should not be considered secure.

9. Updating or Deleting Your Personally Identifiable Information

You have certain rights in relation to your Personally Identifiable Information. You can access your Personally Identifiable Information and confirm that it remains correct and up-to-date, choose whether or not you wish to receive material from us or some of our partners, and request that we delete or provide you with a copy of your personal data by logging into the Site and visiting your user account page and/or by contacting us via the “Contacting AganaMed” section of this Privacy Policy below.

If you reside or are located in the EEA, you are entitled to the rights listed in the “European Union Data Protection” section of this Privacy Policy below.

If you would like further information in relation to your rights or would like to exercise any of them, you may contact us via the “Contacting AganaMed” section of this Privacy Policy below.

10. Cookies Policy

We use cookies on our sites.  Cookies are small pieces of text sent to your web browser by a website you visit. A cookie file is stored in your web browser and allows the Site or a third-party to recognize you and make your next visit easier and the Site more useful to you. Essentially, cookies are a user’s identification card for the AganaMed servers. Web beacons are small graphic files linked to our servers that allow us to track your use of our Site and related functionalities. Cookies and web beacons allow AganaMed to serve you better and more efficiently, and to personalize your experience on our Site.  Cookies can be “persistent” or “session” cookies.

When you use and access the Site, we may place a number of cookies files in your web browser.  AganaMed uses or may use cookies and/or web beacons to help us determine and identify repeat visitors, the type of content and sites to which a user of our Site links, the length of time each user spends at any particular area of our Site, and the specific functionalities that users choose to use. To the extent that cookies data constitutes Personally Identifiable Information, we process such data on the basis of your consent.  In addition to our own cookies, we may also use various third-party cookies to report usage statistics of the Site and refine marketing efforts.

If you’d like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser.  Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use some or all of the features we offer. You may not be able to log in, store your preferences, and some of our pages might not display properly.

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.

11. International Privacy Practices

AganaMed’s Sites are primarily operated and managed on servers located and operated within the United States. In order to provide our products and Services to you, we may send and store your Personally Identifiable Information (also commonly referred to as personal data) outside of the country where you reside or are located, including to the United States. Accordingly, if you reside or are located outside of the United States, your Personally Identifiable Information may be transferred outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your Personally Identifiable Information. We are committed to protecting the privacy and confidentiality of Personally Identifiable Information when it is transferred.

If you reside or are located within the EEA and such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as you would have within the EEA to the extent feasible under applicable law.

12. European Union Data Protection

If you reside or are located in the EEA, you have the right to request that we:

  • Provide access to any Personally Identifiable Information we hold about you;
  • Prevent the processing of your Personally Identifiable Information for direct-marketing purposes;
  • Update any Personally Identifiable Information which is out of date or incorrect;
  • Delete any Personally Identifiable Information which we are holding about you;
  • Restrict the way that we process your Personally Identifiable Information;
  • Provide your Personally Identifiable Information to a third party provider of services; or
  • Provide you with a copy of any Personally Identifiable Information which we hold about you. We try to answer every email promptly where possible and provide our response within the time period stated by applicable law. Keep in mind, however, that there will be residual information that will remain within our databases, access logs, and other records, which may or may not contain your Personally Identifiable Information. Please also note that certain Personally Identifiable Information may be exempt from such requests in certain circumstances, which may include if we need to keep processing your Personally Identifiable Information to comply with a legal obligation. When you email us with a request, we may ask that you provide us with information necessary to confirm your identity.

You may also have the right to make a complaint to the relevant European National Data Protection Authority.  A list of Authorities is available here: https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080

13. Changing Our Privacy Policy

Please note that we review our privacy practices from time to time, and that these practices are subject to change. Any change, update, or modification will be effective immediately upon posting on our Site. We will notify you of any material change to this Privacy Policy by posting a notice on our Site’s homepage for a reasonable period of time following such update or by sending an email to the email address associated with your user account, and by changing the effective date (located at the top and bottom of this page). Be sure to return to this page periodically to ensure familiarity with the most current version of this Privacy Policy.

14. No Information from Children Under 13

AganaMed strongly believes in protecting the privacy of children. Any use or access by anyone under the age of 13 is prohibited, and certain regions and Content Offerings may have additional requirements and/or restrictions. In line with this belief, we do not knowingly collect or maintain Personally Identifiable Information on our Site from persons under 13 years of age, and no part of our Site is directed to persons under 13 years of age. If you are under 13 years of age, then please do not use or access this Site at any time or in any manner. We will take appropriate steps to delete any Personally Identifiable Information of persons less than 13 years of age that has been collected on our Site without verified parental consent upon learning of the existence of such Personally Identifiable Information.

15. Contacting AganaMed

If you have any privacy-related questions, suggestions, unresolved problems, or complaints, you may contact us as follows:

Email: privacy@aganamed.com

Mail: AganaMed LLC, 268 Bush St #4320, San Francisco, CA 94101, USA.

16. Revisions

Below is a list of all the revisions made to our Privacy Policy, with links to view the difference between each revision.

2020-09-01: Initial release.

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