I. Data Security and Privacy on the GradeHub Portal

The student records obtained from Educational Organizations used in the GradeHub Portal are owned by the respective institutions we serve. GradeHub may use these records and related assessment data for internal business purposes. We collect the following information to analyze exams and provide reports at the question, student, and class levels:

– student IDs
– student and educator names
– student and educator email addresses
– responses to test questions

The GradeHub Portal has a sophisticated security program intended to keep the information stored in the GradeHub Portal protected from unauthorized access. We store your information in a secure data center located in the United States. The GradeHub Portal is configured with data encryption or scrambling technologies and firewalls constructed to the highest industry standards. We also use Secure Socket Layer (SSL) technology that protects the data you send or receive over the Internet. Information on the GradeHub Portal that can be used to “personally identify” students is collected via SSL and encrypted.

Despite the precautions we take with your organization’s data, no system can be completely secure, and there remains a risk that unauthorized access or use, hardware or software failure, human error, or a number of other factors may compromise the security of your information.

The data Educational Organizations provide is used only to provide feedback to the institution’s educators and it’s students. Student information collected on the GradeHub Portal will be used solely for the purposes it was provided to us. We retain student data only as long as necessary to provide services and promptly delete data shortly after service termination.

To review or update your information to ensure its accuracy or to correct any errors and omissions, please contact your Educational Organization directly. Requests sent to GradeHub seeking a copy of such records or demanding that GradeHub to modify or delete any records that it maintains will be forwarded directly to the appropriate Educational Organization.

We will never sell or share student records or other user information with third parties.

We will not advertise to your students.

II. Privacy on the GradeHub Site

Information Collected During Site Use

Although you can visit our Site without telling us who you are, when you access our Site, our servers automatically gather information from your browser, such as your IP Address. Your IP address is a unique number assigned to your computer or device by your Internet Service Provider (ISP). Collecting IP addresses is a standard practice and is generally done automatically. Our servers may also track additional information, including but not limited to the pages of our Website that you visit or the services you use, the browser you are using, the operating system of your computer or mobile device, and the way you interact with our services.

GradeHub may, from time to time, use a third-party service, such as Google Analytics, to collect and analyze this type of visitor data. We use this information for a number of purposes, including calculating usage levels, diagnosing server issues, improving our Website and services to better accommodate user patterns, and detecting and diminishing security threats.

Use of Internet Cookies and Web Beacons

When you visit the Site, we may store information about your web session and assign you one or more “cookies” and “web beacons.” Your browser will store these cookies on your computer in a small text file. For example, when you decide to login as a Site Customer, we store encrypted information in your browser so you don’t have to login on every page. Permanent cookie files remain on your computer’s hard drive until you delete them manually using your browser or operating system software. You may wish to delete such cookies periodically from your computer. You can enable your browser to refuse cookies, but doing so may disable access to some services and tools that we offer. Under no circumstances will cookies or web beacons be used to market to students.

Email marketing

Email marketing sent by GradeHub may contain web beacons and other similar technologies to track the response rate to such communications. Web beacons (also known as pixel gifs, pixel tags, clear gifs, third-party pixels, or targeting pixels) are small graphics with a unique piece of identifying code, similar to a cookie, used to track the online movements of a web user or to access previously set cookies. These tools are used in email communications to determine whether messages have been opened or otherwise acted upon.

Do Not Track

Our services and Site do not respond to your browser’s “do-not-track” signals or comparable mechanisms.

Correspondence Received by GradeHub

Individuals may correspond directly with GradeHub through our “Contact Us” link or through other supplied contact information. Any personal information submitted through such channels will be used only to respond to such communications.

GradeHub does not knowingly collect information about children under the age of thirteen.

III. GradeHub Privacy Shield Statement

This Privacy Shield Statement describes how GradeHub collects, uses, and discloses certain personally identifiable information that we receive in the United States (“U.S.”) from the European Union; the European Economic Area, and Switzerland (“EU Personal Data”). In this Policy, the European Union and the European Economic Area are collectively referred to as the “EU”.

GradeHub recognizes that the EU and Switzerland established strict protections regarding the handling of Personal Data, including requirements to provide adequate protection for EU Personal Data transferred outside of the EU and Switzerland, respectively. To provide adequate protection for certain Personal Data relating to website visitors, customers, prospective customers, partners, vendors, third party suppliers and contractors that GradeHub receives in the U.S., GradeHub has elected to self-certify to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks administered by the U.S. Department of Commerce (“Privacy Shield”). GradeHub adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability.

For purposes of enforcing compliance with the Privacy Shield, GradeHub is subject to the investigatory and enforcement authority of the U.S. Federal Trade Commission. For more information about the Privacy Shield, see the U.S. Department of Commerce’s Privacy Shield website located at https://www.privacyshield.gov.

Types of Personal Data Collected

GradeHub collects Personal Data (i) from individuals who visit our website and voluntarily provide their information, and (ii) from our customers, vendors, contractors, and agents, including the following specific types of information:

– Contact information – name, address, email address, and phone number
– Student records – education customers Ÿprovide student ids and grades
– Professional and employment information
– financial information and identification information, including driver’s license and passport numbers

Purposes of Personal Data Collections and Use

GradeHub collects, uses and processes Personal Data for the purposes of:

Ÿ- Providing information about our products, services, and events
– Providing products, services, and support to our customers Ÿ
– Communicating with business partners, vendors, agents, and contractors about business matters
– Analysis of information in order to improve business practices, products, and services
– Conducting related tasks for legitimate business purposes
– Other purposes disclosed at the time of collection Ÿ
– Compliance with legal requirements

GradeHub will only process Personal Data in ways that are compatible with the purpose for which GradeHub collected the Personal Data, or for purposes that the individual or entity providing the Personal Data later authorizes. Before we use your Personal Data for a purpose that is materially different than the purpose for which it was collected or that you later authorized, we will provide you with the opportunity to opt out. GradeHub maintains reasonable procedures to help ensure that Personal Data is reliable for its intended use, accurate, complete, and current.

We may collect or our customers may provide to us when using GradeHub services, certain Personal Data that is regarded as “sensitive,” including data concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, or data concerning health or sex life. When we directly collect sensitive Personal Data, we will obtain opt-in consent where the Privacy Shield requires, including if we disclose sensitive Personal Data to third parties, or before we use sensitive Personal Data for a different purpose than we collected it for or that the data subject later authorized.

Data Transfers to Third Parties

Third Party Agents or Service Providers

We may transfer Personal Data to our third party agents or service providers that perform functions on our behalf. Where required by the Privacy Shield, we enter into written agreements with those third party agents and service providers requiring them to provide the same level of protection that the Privacy Shield requires and limiting their use of the data to the specified services provided on our behalf. We take reasonable and appropriate steps (i) to ensure that third party agents and service providers process Personal Data in accordance with our Privacy Shield obligations and (ii) to stop and remediate any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third party agents or service providers that perform services on our behalf for their handling of Personal Data that we transfer to them.

Third Party Data Controllers

In some cases, we may transfer Personal Data to unaffiliated third party data controllers. These third parties do not act as agents or service providers and are not performing functions on our behalf. We may transfer your Personal Data to third party data controllers for the following purposes:

Sponsors and exhibitors at certain GradeHub events receive Personal Data about attendees, which the sponsors and exhibitors may use for their own promotional purposes. To facilitate the provision of services to GradeHub customers, GradeHub may provide Personal Data to third-party software and services companies whose products interact with GradeHub products and services in certain instances where a GradeHub customer is also a client of such third party.

We will only provide your Personal Data to third party data controllers where you have not opted-out of such disclosures. We enter into written contracts with any unaffiliated third party data controllers requiring them to provide the same level of protection for Personal Data that the Privacy Shield requires. We also limit their use of your Personal Data so that it is consistent with any consent you have provided and with the notices you have received. If we transfer your Personal Data to one of our affiliated entities within our corporate group, we will take steps to ensure that your Personal Data is protected with the same level of protection that the Privacy Shield requires.

Security

GradeHub maintains reasonable and appropriate security measures to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield.

Access Rights

You may have the right to access the Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your Personal Data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances, we may charge a reasonable fee for access to your information. If your Personal Data was provided to us by a GradeHub customer, we may facilitate your access to such data by directing you to the customer that provided your data to us.

Questions and complaints

In compliance with the Privacy Shield Principles, GradeHub commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact GradeHub at privacy@GradeHub.com. GradeHub has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your Privacy Shield complaint from us, or if we have not addressed your Privacy Shield complaint to your satisfaction, please contact or visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim for more information or to file a complaint. The services of JAMS are provided at no cost to you.

Binding Arbitration

You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have first taken the following steps: (1) raised your complaint directly with GradeHub and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority and allowed the U.S. Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see U.S. Department of Commerce’s Privacy Shield Framework: Annex I (Binding Arbitration) at http://ec.europa.eu/justice/data-protection/files/annexes_eu-us_privacy_shield_en.pdf.

IV. Protecting Your Privacy

We take every step possible to protect your privacy at all times. We also employ security measures to protect personal information in storage. The data will always remain protected. We will use any information we gather only to help us understand your needs and make our website or products more valuable to you. We will not provide any personal information to other companies or individuals without your permission and we won’t sell your personal information to anyone.

GradeHub may disclose to authorized law enforcement personnel the personal data from anyone who poses a threat. This might include those that are attempting to commit fraud or those who conduct activities that could bring harm to others.

V. Disclosure to Third Parties

As a general rule, we will not give your data to third parties for direct marketing purposes without your permission. However, there are some important exceptions to this rule that are described in the following paragraphs and the paragraphs above.

We may, in our sole discretion, provide information about you to comply with a court order, law or legal process, to law enforcement or other government officials for purposes of fraud investigations, alleged intellectual property infringement, or any other suspected illegal activity or matters that may expose us to legal liability or infringe on our rights or the rights of third parties.

We may provide information about you to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about our website users is among the assets transferred. In the event of such a transaction, any successor entity that acquires your information will continue to be subject to the terms and conditions of this Privacy Policy.

We will share information with third parties to fulfill the explicit purpose for which you provide it. For example, we will post information that you enter into our blog’s comment system to our blog; share information where you give consent; and use information for the purpose that is disclosed by us when you provide the information; we share information with third parties who assist us in operating our business; for example if we use an email-service-provider, we may provide your email to such vendor to assist us in sending email communications.

VI. Autoresponders

We may use autoresponders to communicate with you by e-mail. To protect your privacy, we use a verified opt-in system for such communications and you can always opt-out of such communications using the links contained in each autoresponder message.

VI. Changes to this Privacy Statement

We may update or modify this Privacy Policy to reflect changes in the way GradeHub maintains, uses, shares, or secures your information. Please check this Policy each time you interact with our systems to ensure that you are aware of any revisions. Prior to any material changes to this Policy becoming effective, GradeHub will provide notice to your Educational Organization and allow it the opportunity to make choices regarding the data it stores with GradeHub.

VI.Contact Us

If you have any questions about this Policy or would like to request access to your Personal Data, please contact us as follows:

GradeHub Corporation

Attn: Privacy Officer
5151 California Ave #100
Irvine, CA 92679

USA

+1 (949) 534-6310

privacy@gradehub.com

Effective Date: July 30, 2018.