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Privacy Policy

This Privacy Policy covers EasyLlama, Inc.’s (“EasyLlama”) policies on the collection, use, and disclosure of personal data/personally identifiable and other personal information (as defined by applicable law, including, but not limited to, the California Consumer Privacy Act of 2018, Civil Code sections 1798.100 et seq (“CCPA”)) (collectively referred to as “Personal Information”) in connection with visitors, customers and authorized user’s use and/or access of the e-learning website and platform made available at www.easyllama.com (the “Platform”) and the software and services made available through the Platform (collectively the “Services”).

EasyLlama is a Delaware corporation with offices in the United States. EasyLlama collects Personal Information and processes, transfers and stores data within the United States. By optionally providing your Personal Information within the Platform, you consent to the collection, use and disclosure practices identified in this Privacy Policy.

1. What Personal Information Is Collected?

Personal Information that you may provide to us through the Platform or otherwise includes:

Email & Contact Information. Users may optionally provide their email address and/or other contact information (e.g., name, company name, job title) to EasyLlama to contact us through the Platform with questions about our Platform and Services. Users may also optionally subscribe to our newsletters and may unsubscribe at any time through the opt-out link contained within those communications.

Account Information. In subscribing to, or otherwise purchasing, the Services, EasyLlama requires its customers to provide account-based information, including Customer name, address, phone number, and email. Administrators who assign courses to authorized users will be required to input (manually or through available integrations) the name, email, state and phone number, as well as applicable employment information (office location, supervisor, department, applicable employee ID) to enable assignment and completion status tracking of course licenses. This information is necessary to facilitate account services. EasyLlama will utilize email and/or cellular phone numbers provided to communicate with authorized users regarding course assignment, access and completion status. Account information may also be used to (i) provide information regarding our Services; (ii) communicate material changes to our Terms of Service and Privacy Policy; and/or (iii) help us maintain and improve Services offered.

Payment Information. To make payments for the Services, EasyLlama may collect debit or credit card account information, email and other information to verify the customer’s identity, such as name, address, telephone number, and/or date of birth. EasyLlama does not itself store debit or credit card information on its servers, but utilizes a third party payment processors to manage and process payments in order to guarantee the security of personal payment information.

IP Address. A user’s “IP Address” is identified and logged automatically in our server log files whenever you visit the Platform, along with the time of the visit and the page(s) that were visited. EasyLlama uses IP Addresses for calculating usage levels of the Platform, helping diagnose server problems, and administering the Platform and Services.

Cookies: EasyLlama utilizes cookie technology to gather information on Internet use in order to serve its users more effectively. As described in Section 2, EasyLlama also utilizes third party analytics services which may also use tracking cookies to provide information about the use of our Platform. Users can set their browser to remove or reject cookies and/or accept or refuse cookies on the cookie consent banner on the Platform itself; however, some Platform features or Services may not work properly without cookies.

How You Can Control Advertising Cookies. Cookies are also utilized to deliver advertising on our site. Among other uses, they allow us to show more relevant advertising to people who visit the site by showing you ads that are based on your browsing patterns and the way you have interacted with our sites. You can find information about how to opt out of the cookies provided by our advertising partners here:

  • Google Ads. Google Ads utilizes search engine marketing to serve ads to target audiences. Users can manage ad settings on Google Advertising Opt-Out and revisit their privacy preferences on Google’s Privacy Checkup tool.
  • Facebook Advertising. Facebook, may use cookies, web beacons, and other storage technologies to collect or receive information and use that information to provide measurement services and target ads. EasyLlama may use “Visitor action pixels” from Facebook on the Platform. This allows user behavior to be tracked after they have been redirected to the provider’s website by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we do not see the Personal Information of individual users. Please see the Facebook’s Data Policy for additional information. Users can opt-out of the collection and use of information for ad targeting. To opt-out, go to Privacy Settings through your Facebook account and opt out under the Ad Preferences settings.  
  • Microsoft Ads. In connection with Microsoft Ads and remarketing, EasyLlama uses a Universal Event Tracking (UET) feature, which enables Microsoft to collect or receives Personal Information from you to provide Microsoft Advertising. Please see Microsoft Privacy Statements for more information.   

Even if you opt out of cookies/ads personalization, you may still see ads based on factors such as your general location derived from your IP address, your browser type, and your search terms. You can also manage cookies for any online advertising service via the consumer choice tools created under self-regulation programs, such as the US-based aboutads.info choices page or the European Union (“EU”)-based Your Online Choices. See also the Network Advertising Consumer Opt-Out and/or the Digital Advertising Alliance Opt-Out.

2. Use of Personal Information

EasyLlama uses Personal Information for the following purposes or as otherwise disclosed at the time of collection:

Provide Services. Personal Information is used to:

  • Provide, operate and improve the Platform and Services;
  • Process payments and complete transactions;
  • Update you and provide marketing communications about new features and services;
  • Respond to inquiries and provide customer support and feedback;
  • Analyze data to assess, understand and improve the services and personalize user experiences, including creation of anonymized aggregated, statistical and benchmark data.
  • Aggregated data is utilized to help develop and market products or services and present targeted content and advertising
  • Enable functionality of the services to authenticate a user, prevent fraud, and implement security measures

Service Providers. EasyLlama has engaged with third party service providers to facilitate the EasyLlama services and operate our business, including without limitation, data base management hosting, information technology, email/SMS delivery, customer support, analytics, data security and compliance services necessary to provide the EasyLlama Platform Services.

SMS Notifications – Notice & Consent. EasyLlama utilizes a third party service provider to enable SMS course assignment and status notifications to its customers and its authorized users (as defined in the applicable Terms of Service or Services Agreement). You consent to receive recurring text messages about the EasyLlama assigned e-learning courses and your account to the mobile number associated with assigned EasyLlama courses. You understand and agree that text messages sent to your mobile number may be generated using automated technology, Message and data rates may apply. Reply STOP to opt-out or HELP for info. Consent is not a condition of any purchase.

Analytics: EasyLlama uses the following third party analytics services:

  • Google Analytics: EasyLlama utilizes Google Analytics for data analytics to generate insights and recommendations. For more information please see Google’s Privacy Policy. However, if you do not want your Personal Information to be used by Google Analytics, you may opt-out by installing Google Analytics Opt-out Browser Add-on.
  • FullStory: FullStory records user sessions on their website, enabling meaningful insight into users' experience, as an effective way to identify usability problems and other areas for improvement. For more information on the privacy policy of this service, please see: FullStory Privacy Policy and its Acceptable Use Policy. If you wish to prevent all websites using the FullStory Services to be able to record activity, you can opt-out of the FullStory Services. Opting out will create a cookie that tells FullStory to turn off recording on any site which uses the FullStory Services. The presence of this cookie is required to continue opting out, so if you clear your browser cookies, you will have to opt-out again.
  • HubSpot. EasyLlama utilizes HubSpot to measure the performance of its marketing campaigns. Please see HubSpot's Privacy Policy for more information on their data collection and use practices.
  • Hotjar. In addition to analytics, Hotjar may also use other technologies with similar functionality to cookies, such as web beacons and tracking URLs to obtain Log Data about users. It may also use web beacons and tracking URLs in our messages to you to determine whether you have opened a certain message or accessed a certain link. Hotjar collects information in accordance with its Hotjar Privacy Policy. To disable Hotjar so that it does not collect your data, follow the instructions on Hotjar's Opt-Out Page.

Compliance and Protection. Personal Information may be disclosed to serve our legitimate business interests as follows: (1) as required by law, such as to comply with a subpoena, or similar legal process, (2) if EasyLlama is involved in a merger, acquisition, or sale of all or a portion of its assets, (3) to investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (4) enforce our agreements with you, and/or (5) investigate and defend ourselves against any third-party claims or allegations. We will use commercially reasonable efforts to notify you about law enforcement or court ordered requests for data unless otherwise prohibited by law.

Please see Section 5 for a more specific disclosure of the applicable categories of personal information collected and processed under the CCPA.

3. Compliance with the Children’s Online Privacy Protection Act, CCPA and Other Privacy Regulations Relating to Children

EasyLlama does not knowingly collect Personal Information from anyone under the age of 16. If a parent or guardian becomes aware that his or her minor child as defined by applicable privacy laws has provided Personal Information without their consent, he or she should contact EasyLlama at legal@easyllama.com. We will delete such Personal Information from our files within a commercially reasonable time, but no later than required under the applicable law relating the child’s state and/or country of residence.

4. Retention of Personal Information

Unless erasure is otherwise requested under applicable law or as otherwise stated in this Privacy Policy, EasyLlama will retain account data as long as it is necessary to provide services to our customers. Personal Information obtained from Platform visitors will be maintained as long as it is necessary to provide requested communications and information-based services or until a visitor exercises the right to opt-out of requested communications or information-based services. Anonymized and pseudo-anonymized data will be retained as long as EasyLlama determines such data is commercially necessary for its legitimate business interests.

5. YOUR CALIFORNIA PRIVACY RIGHTS

California Consumer’s Request to Know, Right to Delete, Right to Opt-Out of Sale Notices. For additional information on your California Consumer Rights, please click on the following: Your California Rights - California Consumer Privacy Rights Notice (“Notice”)

  • Right to Know & Delete: A verifiable Consumer Request under this Section to exercise your right to know and right to delete may be submitted to EasyLlama by email at legal@easyllama.com or as otherwise designated in the Notice. For each request, EasyLlama will initially verify the email address on file with the email address submitted in the applicable request. Further verification will be based upon confirmation of data correlating to information maintained by EasyLlama, as applicable. Consumers may designate an authorized agent to make a request on the Consumer’s behalf at legal@easyllama.com. Requests by authorized agents are subject to additional verification requirements pursuant to the rules and regulations set forth in the CCPA.
  • Sale of Personal Information [Under CCPA & Applicable State Laws]: EasyLlama also shares certain Personal Information with third party advertisers. The CCPA broadens the definition of “sale” and “personal information” beyond how you might commonly interpret those terms.  Under the CCPA, “personal information” includes information that is not necessarily directly tied to an individual’s identity but may be associated with a device. This includes identifiers such as IP addresses, web cookies, web beacons.  Similarly, the term “sell” is defined to include not just selling in exchange for money, but also sharing or transferring personal information (including information that does not directly identify an individual as described above) in exchange for anything of value, which is not limited to the exchange of money.   EasyLlama shares data with advertising partners, such as Facebook and Google, to deliver relevant advertising to you.  When you opt out  under this Section, EasyLlama will stop sharing your information with those advertising partners with whom such sharing is considered a “sale” under the CCPA. Under applicable state law, certain residents have the right to request that EasyLlama disclose the categories and/or specific pieces of personal information collected and sold and the right to direct us not to sell their “personal information” (“Right to Opt-Out”).

6. EasyLlama’s Security Policy

We have implemented reasonable administrative, technical and physical security measures to protect Personal Information against unauthorized access, destruction or alteration.

7. International Data Transfer

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 you are transferring information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. and the use and disclosure of information about you, including personal information, as described in this Privacy Policy.

8. Response To “Do Not Track” Signals

“Do Not Track” is a feature enabled on some browsers that sends a signal to request that a website disable its tracking or cross-website user tracking.

EasyLlama shall treat any user-enabled global privacy controls, such as a browser plug-in or privacy setting, device setting, or other mechanism, that communicate or signal the consumer’s choice to opt-out of the sale of their Personal Information as a valid request submitted pursuant to the CCPA for that browser or device, or, if known, for the consumer.

9. Notification of Changes to Privacy Policy

If we make material changes to our Privacy Policy, we will notify you by either (i) changing the Effective Date at the top of the Privacy Policy, or (ii) sending an electronic notification to all active account holders, or (iii) adding a banner/notification to the Platform itself. Express consent will be obtained when required for any material changes in EasyLlama’s collection and use practices as required by applicable law.

10. Contact Us

If you have any questions regarding your Personal Information or about our privacy practices, please contact us at: 340 S LEMON AVE #3753 WALNUT, CA 91789 and/or at legal@easyllama.com.

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