Privacy Policy/Privacy Notice

Last Modified: November 1, 2020

Protecting your private information is our priority. This privacy policy (“Privacy Notice”) relates to the information collection and use practices LI2EI, LLC (hereinafter, variously “Company”, “we”, “us”, or “our”) in connection with our website www.li2ei.com (the “Site”), any other websites we may have now or in the future our software-as-a-service solution, and our mobile application (collectively, the “Services”).

We strive to educate parents and kids about how to appropriately safeguard their privacy when using our Services. We are committed to complying with the Children’s Online Privacy Protection Act of 1998 (“COPPA”), which requires us to inform parents and legal guardians about our information collection and use practices. COPPA also requires that we obtain parental consent before we allow children under the age of 13 to access and/or use our Services. We urge kids to check with their parents before entering information through our Site and/or Services, and we recommend that parents discuss with their kids restrictions regarding the online release of Personal Information (as defined below) to anyone they don’t know.

By visiting our Site and/or using the Services in any manner, or by permitting your child to use our Services, you are agreeing to the terms of this Privacy Notice and the accompanying Terms of Use and consent to the data practices described herein and therein. If you do not accept this Privacy Notice or do not meet or comply with the provisions set forth herein, then you may not use the Services. If required by applicable law, we will seek your express consent to process personal data (i) provided by you and/or (ii) collected during your use of the Services. Any consent shall be entirely voluntary. In the event you do not provide consent to use or process your personal data, then you may not access and/or use the Services. Capitalized terms not defined in this Privacy Notice shall have the meaning set forth in our Terms of Use.

I. INFORMATION WE COLLECT

Personal Information

We do not collect any personal information from you unless you voluntarily provide it to us.

When you sign up to become a user of the Site (a “User”), you will be asked to provide us with certain personal information, such as your first name, last name and e-mail address for the purpose of providing to you content and/or services that you request. We may collect Personal Information such as your: (i) personal and/or business contact information (including name, telephone number, email and address, device identifier, and business website address); (ii) financial information (such as checking account information, credit card number, expiration date, verification number, and billing address); (iii) username and password; (iv) demographic information (including age, birthdate and gender); (v) location information (such as geographic location of the device you are using); (vi) preferences and behavior (such as record of comments, responses and questions asked); (vii) school account information, if applicable, and/or (viii) academic performance related information. Once you register, you have opted in to receive electronic communications from the Company. Please note that some of the foregoing information will only be asked when an adult is registering an account. The company may also provide you with the opportunity to participate in surveys through the Services. If you participate, we will request certain personally identifiable information. Participation in surveys is completely voluntary and you therefore have a choice whether to disclose such information.

Other than the online contact information required to obtain parental consent, we do not collect any Personal Information from Users under the age of 13 unless the User’s parent or legal guardian has first provided us with consent for that User to use the Services and disclose Personal Information to us. If you are a User under the age of 13, please do not send any Personal Information to us if we have not obtained prior consent from your parent or guardian. If we learn we have collected Personal Information from a User under the age of 13 without parental consent, or if we learn a User under the age of 13 has provided us Personal Information beyond what we request from him or her, we will delete that information as quickly as possible. If you believe that a User under the age of 13 may have provided us Personal Information in violation of this Privacy Notice, please contact us at contact@li2ei.com.

Credit Card and Payment Information. Please note that when your bank account information or credit card information is transmitted via the Services, it will be protected by encryption technology used by one of our third-party payment processors, Stripe or Apple. The Company does not store credit card details and instead utilizes Stripe or Apple to process payments made to us. In connection with the processing of such payments, we do not retain any personally identifiable information or any financial information such as credit card numbers. Rather, all such information is provided directly to our third-party payment processor, whose use of your personal information is governed by their privacy policy.

Additional Information for School Accounts. If you have access to the Services through an account for schools, school districts, licensed childcare facilities or other licensed educational institutions or programs (each “Educational Account”), additional privacy protections apply because your Educational Account may provide us with personally identifiable information of students (“Student Data”) as defined by the Family Educational Rights and Privacy Act 20 U.S. C. § 1232g and its implementing regulations (34 CRF Part 99) (collectively, “FERPA”). We will only access, collect, record, organize, use or disclose Student Data collected through the services as described in any relevant agreement with the applicable Educational Account and this Privacy Notice.

Information We Collect Automatically (“Automated Information”). When you access and/or use the Services, we may collect Automated Information about you through the use of cookies, and other technologies. Please see our Cookies Policy for more information on cookies. In addition to cookies, such other technologies may include. Like most websites, we use automatic data collection technology when you visit the Site to record information that identifies your computer, to track your use of our Site, and to collect certain basic information about you and your surfing habits. This information includes information about your operating system, your IP addresses, browser type and language, referring and exit pages and URLs, keywords, date and time, amount of time spent on particular pages, what sections of a website you visit, and similar information concerning your use of the Site and the Services (the “Usage Information”).

Cookies. We collect this Usage Information by using cookies and pixel tags (also called web beacons or clear gifs). We use Cookies and web log files for the primary purpose of providing the functionality of the website itself. A “Cookie” is a tiny data file that resides on your computer, mobile phone, or other device, and allows the Company to recognize you as a user when you return to our website using the same device and web browser and enables the Company to collect information about how you use our Services. Information gathered through Cookies may include the date and time of visits, the pages viewed, and time spent at using the Service. If you do not agree to our use of Cookies, you should set your browser settings accordingly or not use the Services. the Company uses Cookies and web log files for the following, which may include without limitation (i) to track usage and trends, (ii) to improve the quality of the Services, (iii) to customize your experience and/or (iv) to compile anonymous, aggregated information that allow us to understand how our Services are used. Cookies are categorized by how long they are stored and their function. The Cookies the Company uses are as follows:

Session Cookies: Session Cookies are temporary and deleted from your computer when you close your web browser. They allow the Company to link the actions of a user while using the Services.
Performance Cookies: Performance Cookies collect anonymous data for statistical purposes on how users use the Services, they don’t contain personal information and are used to improve the user experience.
Strictly Necessary Cookies: Strictly necessary Cookies are essential to navigate around the Services and to use its features.
Persistent Cookies: Persistent Cookies remain on a visitor’s device for a set period of time specified in the Cookie. They are activated each time the visitor visits the Services that created that particular Cookie.

You may remove or block Cookies using the settings in your browser, but in some cases that may impact your ability to use our Services and/or user experience while using the Services. By accessing or using the Services, you consent to the placement of Cookies on your device as described in this Privacy Notice. If you prefer not to receive Cookies through the Services, you may control how your browser responds to Cookies by adjusting the privacy and security settings of your web browser. Please note, in some cases that may impact your ability to use the Services and/or user experience while using the Services.

Device Data. We use device data, which is information concerning a device you use to access, use, and/or interact with the Services, such as operating system type and/or mobile device model, browser type, domain, and other system settings, the language your system uses and the country and time zone of your device, geo-location, unique device identifier and/or other device identifier, mobile phone carrier identification, and device software platform and firmware information.

Aggregate. We may collect non-identifying and statistical information about the use of our Services, such as how many visitors visit a specific page, how long they stay on that page and which links, if any, they click on, system configuration information and/or other interactions with the Services. This information represents a generic overview of our users, including their collective habits. Information collected in the aggregate is not associated with you as an individual.

Analytics. We use analytic software to gather statistics and usage trends for product and service improvement purposes. The Service may record data from your phone, tablet, or computer such as how frequently you use the Service, what actions you take and performance data.

Other Tracking Technologies. We may supplement information you provide to us with information from other sources, such as information to validate and/or update your address, payment card and/or other demographic information. This information is used to maintain the accuracy of information on our Services and for internal analysis. We may also use clear gifs, pixel tags and web beacons, which are tiny graphic images placed on website pages and/or in our emails that allow us to determine whether you have performed specific actions and are further used to track online movements of our users. In contrast to Cookies, which are stored on your computer’s hard drive, clear gifs are embedded invisibly on web pages. We do not tie the information gathered by clear gifs to your personally identifiable information.

The above tracking technologies may be deployed by us or our service providers on our behalf, as set forth below. Automated Information includes information such as:

IP address
Operating system used (for example: iOS)
Internal resolution of the browser window
Device type
Country code
Identifiers associated with technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address)
Dates and times of access
IDFA
Subscription information
Latitude/longitude (if you allow location tracking)
AdvertisingID (such as Google’s AdvertisingID and Apple’s IDFA, both of which are randomly generated numbers that you can reset by going into your device’s settings)
Adjust ID (this identifier lets us know where our users found our Services online, record user app events and optimize our advertising efforts)

We or our third-party service provider may assign you a unique identifier through automated means in order to match information collected from you through different means or at different times, (including both personal information and Automated Information) and to use such information as described in this Privacy Policy.

Third-Party Services. To support the services we provide to you, we may use services hosted by third parties that may use Cookies and various tracking technologies and may collect information sent by a browser as part of a web page request, including ‘Internet Protocol’ addresses, browser software, and/or clickstream patterns. If such third-party services collect information, they do so anonymously without identifying individual visitors. However, we may link the information we record using tracking technology to personal information we collect.

II. HOW WE USE YOUR INFORMATION

General Use

We may use your Personal Information and Usage Information collected as described in this Privacy Notice to provide you with the Services and/or information and/or content that you have requested, and, in some cases, to contact you about our products, features and/or other services. We will also use the information collected to take the following actions:

operate, maintain and improve the Services;
answer questions and respond to your requests;
perform analytics and conduct research;
send you reminders, support and marketing messages;
manage our administration of the Services;
improve the design and content of the Services;
analyze programs, products and services we offer;
contact you through email, social media, blog or newsletter;
collect feedback from you about third-party products and/or services;
provide tailored ads based on your information and/or preferences provided while using the Services;
inform you about products, events and/or other promotional purposes;
inform Educational Accounts and/or parents of students progress and data related to the use of the Services; and
use information for other purposes about which we notify you.

The information collected in the aggregate enables us to better understand your use of the Services and to enhance your enjoyment. We may use financial information to enroll you in one of our accounts and/or other related services in which you elect to participate. If you use the Services, you agree to receive certain communications from us including but not limited to the following:

Special Offers, Newsletters and Updates. We will occasionally send you information on products, special deals, promotions and newsletters. Out of respect for your privacy, you may elect not to receive these types of communications by contacting us at contact@li2ei.com.

Customer Service. Based upon the personally identifiable information you provide us, we will communicate with you in response to your inquiries and reviews, to provide the services you request and to manage your account. We will communicate with you by email, through the Services, or telephone, as you may elect. You can reach the Company by email at contact@li2ei.com. or phone at 626-532-3329.

III. Parties with whom we may share your information

We take the privacy of our users very seriously, and we do not sell, rent, and/or otherwise provide your personally identifiable information to third parties for their direct marketing purposes.

Service Providers. We, like many businesses, sometimes hire other companies to perform certain business-related functions. Examples include mailing information, maintaining databases, hosting services, and processing payments. When we employ another company to perform a function of this nature, we provide them with the information that they need to perform their specific function, which may include Personal Information. We may share your personally identifiable information as well as information from tools like Cookies, log files, and device identifiers and location data (such as usage data, referring/exit pages and URLs, platform types, number of clicks, etc.), with employees, contractors, third-party providers and/or agents that help us provide the Services to you (the “Service Providers“). Our Service Providers will be given access to your information as is reasonably necessary to provide the Services. We will not share your personally identifiable information in ways unrelated to those described in this Privacy Notice without providing you with an opportunity to opt out of such use or otherwise prohibit such unrelated use. Certain Service Providers will automatically collect non-identifying information about your use of the Services and the Company shall not have any liability related thereto. Notwithstanding the foregoing, the Company reserves the right to sell non-identifying information and data (such as gender, age group, cities, states, rewards, content selected, etc.), collected in the aggregate, to outside third parties.

Compliance with Laws. The Company will not disclose your personal information to third parties except as set forth in this Privacy Notice and in the following circumstances: (i) to investigate and defend Company members against any third-party claims and/or allegations and/or otherwise to protect the Company from liability, (ii) to investigate, prevent and/or take action regarding suspected and/or actual illegal activities, (iii) to assist government enforcement agencies, respond to a legal process and/or comply with the law, (iv) to exercise or protect the rights, property and/or personal safety of the users of the Services and/or (v) to protect the security and/or integrity of the Service. Service Providers may share your personal identifiable information as well as non-identifying information to comply with legal obligations. For example, in connection with an unauthorized, fraudulent, or illegal payment, a third-party Service Provider may share any information related to such activity with the appropriate financial institution, regulatory authority, or law enforcement agency consistent with its legal obligations. This information may include information about you and the payment transactions made. Notwithstanding anything herein to the contrary, the Company is not responsible for any losses, whether direct or indirect, that you may incur as a result of the Company or the Service Provider’s response to a request for disclosure of personal information or non-identifying information required by law.

Business Transfer. If we sell or otherwise transfer part or all of the Company or our assets to another organization (e.g., in the course of a transaction such as a merger, acquisition, bankruptcy, dissolution, liquidation, etc.), your information such as name and email address, user content and/or any other information collected through the Services may be among the items sold and/or transferred.

Sharing with Authorized Parties. We may share information about a student’s use of the Services with schools, teachers and/or parents in order to provide the Services, curriculum and reward details needed to assist with classroom management, differentiation, and curriculum.

IV. How We Protect Your Information

We use commercially reasonable efforts to secure your personal information from unauthorized access to and/or unauthorized alteration, disclosure and/or destruction of information we hold. We have adopted appropriate physical, electronic and managerial procedures to safeguard and secure the personal information we process. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. Your account is protected by password for your privacy and security. We periodically review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems. Because the internet is not a completely secure environment, the Company cannot warrant the security of any information you transmit to the Company or guarantee that information on the Services may not be accessed, disclosed, altered, and/or destroyed by breach of any of our physical, technical and/or managerial safeguards. In particular, e-mail sent to or from us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail. Please do your part to help the Company. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to emails between you and the Company, at all times. Please limit your access to your computer and/or mobile device and/or browser by signing off after you have finished accessing your account. We are not responsible for the functionality, privacy and/or security measures of any other organization.

V. Accessing and Modifying Account Information

You may update the information that is stored in your user account by visiting the Site or by e-mailing us at support@li2ei.com

We strive to help parents ensure that their kids have a safe experience using our Services. Parents or legal guardians can review any Personal Information collected about their child under 13 years of age, have this information deleted, request that there be no further collection or use of their child’s Personal Information, and/or allow for our collection and use of their child’s Personal Information while withholding consent for us to disclose it to third parties. We take steps to verify the identity of anyone requesting information about a child and to ensure that the person is in fact the child’s parent or legal guardian.

VI. Your Information Choices

We respect your privacy and give you an opportunity to opt out of receiving announcements of certain information. Although we think that you benefit from a more personalized experience when we know more about you and what you like, you can limit the information you provide to the Company, and you can limit the communications that the Company sends to you. If you visit the Services and volunteer personally identifiable information, you can opt out of receiving notifications, such as newsletters, and you may review, modify, update, and/or delete such personally identifiable information. You may do so by visiting the Site or by e-mailing contact@li2ei.com. Please be aware that we may still email you non-commercial emails related to your account and your transactions through the Services.

VII. CHILDREN’S PERSONAL INFORMATION

Children and Minors.

We do not collect personal information directly from children under 13. Any personal information about children that we receive, process or store comes from one of two sources: parents who share information about their children, or Educational Accounts where schools or districts who share information about the students in their charge. If you are under eighteen (18), you may use the Services only with the involvement of a parent or guardian. Other than in the places and for the purposes explicitly disclosed in this Privacy Notice and/or the Children’s Privacy Disclosure, we do not knowingly collect personal information from children under the age of thirteen (13) without the explicit consent of the child’s parent or guardian. For more information, please see our Children’s Privacy Policy. If we learn that we have collected personal information from a child under the age of thirteen (13) without parental consent, we will delete such information as quickly as possible. If you believe that a child under the age of thirteen (13) may have provided us personal information without the proper consent, please contact us at contact@li2ei.com.

VIII. Changes to This Privacy Notice

This Privacy Notice is effective as of the date stated at the top of this Privacy Notice. We may update this Privacy Notice at any time, with or without advance notice, so please review it periodically. We will update the ‘Last Modified’ date above and may provide you additional forms of notice of modifications and/or updates as appropriate under the circumstances. You can determine when this Privacy Notice was last revised by referring to the date it was “Last Modified” above. Your continued use of the Services after any modification to this Privacy Notice will constitute your acceptance of such modifications and/or updates.

IX. DATA RETENTION

We will retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use and/or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. Following termination and/or deactivation of your account, we may retain information (including without limitation your personally identifiable information) for a commercially reasonable time for backup, archival, audit purposes, and/or to comply with legal obligations, resolve disputes and enforce agreements. In some cases, if you choose not to provide the Company with requested information, you may not be able to use and/or access all of the Services. You can request further details of retention periods for different aspects of your personal data by contacting us.

X. DATA TRANSFERS

Important Notice to Users Outside the U.S.

The Site and the Services are operated in the United States. The Services are subject to United States laws, including those governing privacy and security of your information. By using the Services, you agree and consent (and represent that you have the authority to provide such consent) to the information collection, use and sharing practices described in this Privacy Notice and understand that the laws of the United States and other countries and territories related to the foregoing may differ from those of other countries and may not be as protective as the laws in the country where you reside. Regardless of the laws in place in such countries, we will treat the privacy of your information in accordance with this Privacy Notice. If you are located outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By providing us with any information through the Site or the Services, you consent to this transfer.

XI. OTHER WEB SITES AND SERVICES

The Site may contain content, services, advertising and other materials that link to websites operated by third parties. We have no control over those other sites, and this Privacy Notice does not apply to them. We are not responsible for the practices employed by any websites and/or services linked to and/or from the Services, including the information and/or content contained therein. Please remember that when you use a link to go from the Services to another website and/or service, our Privacy Notice does not apply to such third-party websites and/or services. Your browsing and interaction on any third-party website and/or service, including those that have a link on the Service, are subject to such third party’s own rules and policies. In addition, you agree that we are not responsible and do not have control over any third parties that you authorize to access your personal information. If you are using a third-party website and/or service and you allow them to access your personal information, you do so at your own risk.

XII. LANGUAGE

The governing language of this Privacy Notice is English, which shall prevail over any other languages used in any translated document.

XIII. HOW TO CONTACT US

If you have questions and/or comments about this Privacy Notice, please email us at contact@li2ei.com.

Because email communication is not always secure, please do not include credit card or other sensitive personal information in your emails to us.

XIV. YOUR CALIFORNIA PRIVACY RIGHTS

California Information Sharing Disclosure

If you are a California resident, please review the following additional disclosures which explain your rights under the California Consumer Privacy Act (“CCPA”), and summarize how we collect, utilize and disclose your and your children’s personally identifiable information.

California Civil Code Sections 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicate that organizations should disclose whether the following categories of personal information are collected, transferred for “valuable consideration,” or transferred for an organization’s “business purpose” (as those terms are defined under California law). We do not “sell” your personal information. The table below indicates the categories of personal information we collect and transfer in a variety of contexts. Please note that because this list is comprehensive, it may refer to types of information that we collect and share about people other than yourself. For example, while we transfer credit card or debit card numbers for our business purpose in order to process payments for orders placed with us, we do not collect or transfer credit card or debit card numbers of individuals that submit questions through our website’s “contact us” page.

Categories of Personal Information That We Collect	To Whom We Disclose Personal Information for Business Purpose
Identifiers – this may include name, postal address, phone number, unique personal identifier, online identifier, internet protocol (IP) address, device ID, email address, account name, signature, social security number, driver’s license number, passport number, or other similar identifiers.	· Advertising networks · Affiliates or subsidiaries · Business partners · Data analytics providers · Government entities · Internet service providers · Operating systems and platforms · Other Service Providers · Payment processors and banks · Product and service fulfillment companies · Social media platforms & networks
Financial information – this may include bank account number, credit or debit card number, or other financial information.	· Government entities · Internet service providers · Operating systems and platforms · Other Service Providers · Payment processors and banks · Service fulfillment companies
Protected characteristics – this may include race, gender, physical or mental disability, and religion.	· Affiliates or subsidiaries · Government entities · Other Service Providers
Commercial information – this may include information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	· Advertising networks · Affiliates or subsidiaries · Business partners · Data analytics providers · Government entities · Internet service providers · Operating systems and platforms · Other Service Providers · Payment processors and banks · Product and service fulfillment companies · Social media platforms & networks
Network activity data– this may include internet or other electronic network activity information, such as browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement.	· Affiliates or subsidiaries · Data analytics providers · Government entities · Internet service providers · Operating systems and platforms · Other Service Providers · Social media platforms & networks
Geolocation data – this may include precise physical location.	· Data analytics providers · Internet service providers · Other Service Providers
Electronic and sensory data – this may include audio, electronic, visual, thermal, olfactory, or similar information (e.g., pictures, a recording of a customer service call, security video surveillance footage).	· Government entities · Other Service Providers
Professional/employment information – this may include occupation and professional references.	· Government entities · Other Service Providers
Education information – such as information contained in education records.	· Government entities · Other Service Providers
Inferences – drawn from any of the information listed above to create a profile

Your California Right of Access to, Deletion of, and to Obtain a Copy of Your Personal Information

Under the CCPA, California residents are entitled to receive access to, deletion of, and to obtain a copy of his or her personal information. You may write us and ask for records of any and all personal information and you may request deletion of your personal information or additional information regarding our collection practices at contact@li2ei.com.or phone at 626-532-3329.

The CCPA requires businesses to disclose (1) the categories of personal information the business collected about Individuals, (2) the categories of sources from which personal information is collected, (3) the business or commercial purpose for collecting or selling personal information, (4) the categories of third parties with whom the business shares personal information, and (5) the specific pieces of personal information the business has collected about the Individual. To obtain such information from the Company, please email your request to contact@li2ei.com and we will provide a list of categories of personal information disclosed within thirty (30) days of receiving such a request. This request may be made no more than once per calendar year. We reserve the right not to respond to requests submitted in ways other than those specified above. The following exceptions may prevail with respect to fulfillment of data access requests: (a) the Company may not provide personal data to you, if management determines that we cannot identify you in our systems because the data we have has been de-identified to the extent that identification is not possible; and/or (b) the Company may not provide personal data to you, if you are involved in a civil or criminal proceeding with the Company.

Recipients of marketing emails are required to have an unsubscribe option under CAN SPAM. Most major Email Marketing Services (EMS) automatically include unsubscribe.

See 15 USCS § 7704 Sec. (5) (“Inclusion of identifier, opt-out, and physical address in commercial electronic mail. It is unlawful for any person to initiate the transmission of any commercial electronic mail message to a protected computer unless the message provides…

(ii) clear and conspicuous notice of the opportunity under paragraph (3) to decline to receive further commercial electronic mail messages from the sender.)