PRIVACY POLICY AND COOKIE STATEMENT

Last Updated: Aug. 21, 2019

Please read this Privacy Policy and Cookie Statement which applies to this Website (as used herein the term “Website” includes “Services,” such as Grafstate, that are associated with the Website) and any other websites, products, and services provided by Cynsight, LLC, a Georgia Limited Liability Company (referred to herein as “Cynsight,” “we” and “our”). If you have any questions about this Privacy Policy and Cookie Statement, please feel free to email us at support@grafstate.com.

A. Information Collected

Cynsight may collect several types of information from and about users of our Website, including information:

• by which you may be personally identified, such as name, email address, country of residence, student number, and name of educational institution (personal information including “Registration Data,” as described below);

• that is about you but does not identify you, such as statistical data; and

• about your internet connection, the equipment you use to access our Website, usage details, your computer’s operating system, Internet Protocol (IP) address, access times, browser type and language, referring Web site addresses, and information collected through cookies, web beacons and other tracking technologies.

Cynsight may collect this information:

• automatically as you navigate through the Website;

• from third parties, for example, through third party analytics software such as Google Analytics; and

• directly from you when you provide it to us.

We may collect personally identifiable information, data that could potentially be used to identify a particular person, or other information that you provide to us. Examples of information that you provide to us include:

• Personal information – When you register for the Website, you provide information about yourself (“Registration Data”) that can include first name, last name, email address, and password. Cynsight uses an account verification service that emails you a validation code, and allows us to verify that your email address is correct.

• Uploaded content – When you voluntarily submit or post code or other information on or through the Website, this code or other information may be made available to, and may be accessed, viewed, stored, collected or used, by other users of the Website, including educators, tutors, mentors, and other students. For example, you may be required to type your name when submitting homework assignments. Your professor and/or his or her teaching assistants may access your homework to perform grading and to provide comments.

• Support requests – When you send a support request or other communication to Cynsight, we may retain those communications to process your inquiries, to respond to your requests, and to improve our Website.

• Activity information – We may track or maintain a log of your activity on the Website, including, but not limited to, session id, navigation path, time stamp, dwell time or time spent using a particular feature, or when you submit assignments or upload code.

Cynsight does not currently collect credit card or billing information when you use or subscribe to our Website. We also do not use third party payment processors to verify payment transactions.

B. How Information Is Used

Cynsight’s purpose in collecting non-personally identifying information is to better understand how visitors and users use our Website. Cynsight does not sell or rent your information, or use your information to serve advertisements. Any of the information we collect from you or about you may be used in one or more of the following ways:

• Providing Services including helping users better understand concepts in the field of science, technology, engineering and math;

• Maintaining, protecting, and improving the Website;

• Performing diagnostics and ensuring the technical functioning of our Website;

• Providing email and other communications to our users related to your use of our Website;

• Integrating our Website with select services provided by Google and Amazon; and

• For any other lawful purpose with your consent.

We may also disclose the information that we collect under other circumstances, as permitted or required by law.

In the event that Cynsight sends you commercial communications regarding your use of our Website, you will be given the opportunity to indicate that you wish to unsubscribe from receiving such future communications.

C. Your Rights

We respect your right to privacy and will follow all applicable laws and regulations concerning collecting, holding, using, and disclosing personal information such as your Registration Data. You may update your Registration Data through the Website, or email us at support@grafstate.com if you wish to correct your Registration Data or other personal information that we may maintain.

We will retain your information for as long as your account is active or as needed to provide our Website. Cynsight may delete your Registration Data following a period of inactivity of your user account, or if you email us to indicate that you no longer wish to use the Website. We reserve the right to retain and use your information as necessary to comply with our legal obligations, and to enforce our agreements.

D. The Family Education Rights and Privacy Act (“FERPA”)

The Family Educational Rights and Privacy Act (“FERPA”) (20 U.S.C. § 1232g; 34 CFR Part 99) is a Federal law that protects the privacy of student education records. The disclosure of certain personal information that you provide to us and/or information that we may create that pertains to you may be limited under FERPA. You may have specific rights under FERPA related to certain personal information, including the right to access and/or update your personal information.

You and Cynsight acknowledge that (a) Website data may include personally identifiable information from education records that are subject to FERPA (“FERPA Records”); and (b) to the extent that Website data includes FERPA Records, Cynsight will be considered a “School Official” (as that term is used in FERPA and its implementing regulations) and will comply with FERPA.

E. Children’s Privacy Rights including Children's Online Privacy Protection Act (“COPPA”)

The Children's Online Privacy Protection Act (“COPPA”) (15 U.S.C. §6501-6506) is a federal law to protect child privacy during use of the internet. Children under 13 (or under 16 in the European Economic Area) should not use the Website. Cynsight does not knowingly request or collect personal information from anyone under the age of 13 (or under 16 in the EEA). If we learn that we have collected personal information from a child under the specified ages, we will take commercially reasonable steps to delete it from the Website’s records.

F. Jurisdiction-Specific Privacy Rights

Users in California

The California Consumer Privacy Act of 2018 (“CCPA”), which is scheduled to be effective on January 1, 2020, does not apply to Cynsight because Cynsight does not meet the definition of a “Business,” as such term is defined in the CCPA. Cynsight also does not share your personal information with third parties for direct marketing purposes, as such terms are defined in California's “Shine the Light” law under Cal. Civ. Code § 1798.83, et seq.

We do not track or honor “Do Not Track” signals sent from any web browser or any other device, mechanism, or software used to access the Website. You can view information about Do Not Track at the following link: https://www.allaboutdnt.org.

To submit any requests for further clarification, please send an email to support@grafstate.com with the subject line “California Privacy Laws,” and including your full name, mailing address, state of residence, and nature of your request in the body of the email.

Users Outside of the U.S.

The Website is intended for use by individuals who are located within the United States. By visiting or using our Website, you consent to storage of your data on servers located in the United States. If you are using the Website from outside the United States, you consent to the transfer, storage, and processing of your data in and to the United States or other countries. Specifically, personal data collected in your geographic location, country (such as Australia), or other area (such as the European Economic Area (“EEA”)) is transferred and stored outside that area. By submitting your data or using our Website, you consent to this transfer, storage, and processing by Cynsight and its processors.

The Website is hosted on Amazon Web Services (AWS). When the General Data Protection Regulation (“GDPR”) applies, the terms in the AWS GDPR Data Processing Addendum between Cynsight (as the Customer) and AWS also apply to enable Cynsight to comply with GDPR contractual obligations. You can view the AWS GDPR Data Processing Addendum at the following link: https://d1.awsstatic.com/legal/aws-gdpr/AWS_GDPR_DPA.pdf. To submit any requests under GDPR, please send an email to support@grafstate.com with the subject line “General Data Protection Regulation,” and including your full name, mailing address, country of residence, and nature of your request in the body of the email.

G. How Information Is Held

As previously noted, information is held and processed in the United States. Cynsight uses commercially reasonable measures to secure and limit access to your personal information so that your personal information will only be processed by individuals specified by Cynsight or any third parties maintaining and developing the Website on behalf of Cynsight.

Due to the Website being accessible on the internet, Cynsight cannot guarantee the security of your personal information. Any transmission of personal information over the internet is at your own risk.

H. Cookie Statement

Cynsight uses cookies and similar tracking technologies like web beacons, pixel tags, or technologies that store information in your browser or device utilizing local shared objects or local storage, such as flash cookies or HTML 5 cookies. We do not use cookies or other tracking technologies for advertising. We use these technologies to deliver, measure, and improve our Website in various ways.

Cynsight uses cookies to help Cynsight identify and track visitors, their usage of the Website, and their preferences. If you do not wish to have cookies placed on your computer you should adjust the settings of your browser to refuse cookies before using the Website. By continuing to navigate this Website without changing your cookie settings, you hereby acknowledge and agree to Cynsight’s use of cookies.

We use cookies for the following purposes.

Authentication and security:

• To log you into Services.

• To protect your security.

• To help detect activities that violate Cynsight’s Terms.

Preferences:

• To remember data about your browser, your preferences, and choices you have made.

Analytics and research:

• To track trends and help us understand how people use the Website.
  
  We also work with Google Analytics and other service providers, who may use cookies and similar technologies to help us analyze how users use the Website. These service providers may either collect data themselves or we may disclose it to them. You can view the Google Privacy Policy at the following link: https://www.google.com/intl/en/policies/privacy/. You can opt out of some of these services through tools like the Google Analytics Opt-out Browser Add-on.

For general information about tracking cookies and how to disable them, visit https://www.allaboutcookies.org.

F. Changes

Cynsight may revise this Privacy Policy and Cookie Statement from time to time. We will post the revised Privacy Policy and Cookie Statement to this page. We may optionally provide additional notice to you through our Website, through our Services, by email, or as required by applicable law. All revisions are effective upon posting and your continued use of the Website after posting of such revisions will be subject to the changed terms of the revisions. You consent to any revisions to this Privacy Policy and Cookie Statement by using the Website following the posting of such revisions.

If you have any questions or concerns about this Privacy Policy, please do not hesitate to email us at support@grafstate.com.