Page 1 of 9 NSLT Privacy Policy National Society for Legal Technology, Inc. and its affiliates (collectively referred to as “NSLT”, “we”, “us”) is committed to protecting personal information. We have an internal Privacy Policy that governs our privacy practices including how we safeguard the personal information collected and our data handling procedures. Our staff are frequently trained and committed to comply with all Family Educational Rights and Privacy Act of 1974 (FERPA) guidelines. This Privacy Notice explains who we are, how we collect, use, and share personal information, and how you can exercise your privacy rights. It applies to educational professionals (such as teachers, instructors, school administrators, authors, editors, and contributors), students at postsecondary schools, adult learners, website visitors, business partners, others whom engage in our products and/or services (“Services”) or who participate in our recruitment activities. We recommend that you read this Privacy Notice in full to ensure you are fully informed. The NSLT entity responsible for your personal information will be the member of NSLT that originally collects your information. This will be explained at the point at which your personal information is first collected by the NSLT entity, for example where you or the institution you work for engages us to provide a service or where we engage you to provide a service to us. What We Do National Society for Legal Technology, Inc. (“NSLT”) is a provider of learning tools that serves the higher education, K-12, professional, library, retail consumer, and workforce training markets worldwide. You can find out more about NSLT at https://www.LegalTechSociety.org/ or by contacting us using the information in the How to Contact Us section. We collect and use information about you if you: • Use one of our website(s) or online learning portals • Purchase or receive one of our Memberships • You are identified as a potential customer • Work with us as a business partner • Apply for employment with NSLT Collection of Your Personal Information “Personal information” is any information that can be used to identify an individual, and may include, name, address, email address, phone number, login information, marketing preferences or payment card number. In many cases, we collect Personal Information directly from you. We will ask you for Personal Information when you interact with us, such as when you register for NSLT Membership on our websites, signup to receive materials electronically, or make a purchase through our online store. We may collect additional information about you from your school, such as information about the classes you are teaching, and from third party data suppliers who enhance our files and help us better understand our customers. We may also collect information from publicly-available social media sites, such as Twitter. Page 2 of 9 When you use our websites, products, and applications, we collect Transaction Information about your session and your activity. In addition to any information that you submit during these sessions, we use cookies and other technological tools to automatically collect information about your computer and your use of our website and applications. We may collect or infer information about you, such as your engagement with our products and with others in your classes. We treat this information as Personal Information when it is associated with other data elements that allow us to identify you. For more information about cookies and other technologies, please see the section Cookies and Other Data Collection Technologies below. We also collect Personal Information when you contact us, such as for customer service purposes so we may assist you with any technical difficulties you are currently experiencing. USE OF OUR WEBSITE(S) OR ONLINE SERVICES The personal information that we may collect about you when you visit our websites or online services broadly falls into the following categories. • Information you provide voluntarily: We collect Personal Information that you provide voluntarily through our websites and online services, for example when completing online forms to register for using our product. The information we collect about you may include some or all of the following: o Name and job title o Company, Organization, School or Institution o Grade level o Contact information, including postal address, telephone numbers and email addresses o Information pertinent to fulfilling our Services to you; and o Any other Personal Information that you voluntarily choose to provide to us. o If we ask you to provide any other Personal Information not described above, the Personal Information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point that you are asked to provide it. • Information that we collect automatically: When you visit our websites, we may collect certain Personal Information automatically from your device. Specifically, this information may include information such as: your IP address, device type, unique device identification number, browser-type, broad geographic location (e.g., country or city-level location) and other technical information. We may also collect information about how your device has interacted with our websites, including the pages accessed, links clicked, and duration of use. Collecting this information enables us to better understand the visitors who come to our websites, where they come from, and what content on our websites is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our websites to our visitors. Some of this information may be collected using cookies and other similar technologies. Page 3 of 9 PURCHASE OR RECEIVED ONE OF OUR SERVICES OR A BUSINESS PARTNER When you engage our Services, we collect Personal Information which is necessary for the performance of those Services. The majority of the Personal Information we collect to provide our Services is supplied voluntarily by our customer and business partners. Because of this, if you are a customer or business partner of NSLT then it will be generally obvious to you what Personal Information we collect. This information broadly falls into the following categories: • Contact information: that allows us to communicate with you, such as your name, username, the company you work for or school you attend, your job title , postal address, telephone numbers, email address or other addresses that allow us to send you messages. • Relationship Information: that helps us do business with you. For students, this may include your school affiliation, expected degree and graduation date, your courses of study, grade level, learning style and how you engage with our products and content, and similar information that can help us tailor our content and offer you personalized instruction. For professionals, this may include your professional credentials and affiliations and the products and services that may interest you. If you are an instructor, we may also collect information about the types of courses you teach, your teaching style and student engagement, and similar information that can help us tailor our content and improve your effectiveness in the classroom. • Transaction Information: about how you interact with NSLT, including your purchase history, information about your use of our content (including time spent on material and results of in-product assessments), customer account information and information about how you use our websites and applications. If you purchase products from us online, we also collect payment card information as needed to process your payment. • Financial information: such as bank account information and billing details in order to manage and process any payments you make to us. • Identification information: such as background information provided by you or collected as part of our business validation process; and • Feedback: information you provide to use about our products and services in order to continuously improve the products and services. POTENTIAL CUSTOMER We collect information directly, from other members of the NSLT group, and from other thirdparty lead providers about organizations who might like to hear from us or receive our products and services. We will only do so in accordance with your preferences and as described in this Privacy Notice. We only collect information from third-party lead providers (conference attendance lists, Listserves, industry magazines, etc.) that you have given permission to for sharing your personal information. • Contact information: such as your name, telephone number, postal address, email address in order to fulfill any order, provide our Services and manage your account. • Demographic information: such as your age and information about your occupation. Page 4 of 9 Uses of Your Personal Information We use your Personal Information in the following ways and where we are satisfied that we have an appropriate legal basis to do so. Our uses broadly fall into the following categories. USE OF OUR WEBSITE(S) OR ONLINE SERVICES • Providing our websites: to perform our contract with you for the use of our websites and to fulfill our obligations under applicable terms of use/service. Where we have not entered into a contract with you, we base the processing of your Personal Information on our legitimate interest to operate and administer our websites and to provide you with the content you access and request (e.g., to download content from our websites). • Providing necessary functionality: to perform our contract with you for the use of our websites. Where we have not entered into a contract with you, we base the processing of your Personal Information on our legitimate interest to provide the necessary functionality required during your use of our websites. • Developing and improving our websites: to analyze trends and to track your usage of and interactions with our websites to the extent it is necessary for our legitimate interest in developing and improving our websites and providing our users with more relevant content, or where we seek you valid consent. • Promoting the security of our websites: by tracking the use of our websites, creating aggregated, non-personal data, verifying accounts and activity, investigating suspicious activity and enforcing our terms and policies, to the extent this is necessary for our legitimate interest in promoting the safety and security of the websites, systems and applications and in protecting our rights and the rights of others. • Assessing and improving user experience: to process device and usage data, which in some cases may be associated with your Personal Information, in order to analyze trends that assess and improve the overall user experience to the extent it is necessary for our legitimate interest in developing and improving the website, or where we seek you valid consent. PURCHASE OR RECEIVED ONE OF OUR SERVICES OR A BUSINESS PARTNER • Providing our services: to provide you with the products, content, or services selected by you or your institution under our contract with you for the use of our Services and to fulfill our obligations under applicable terms of use/service. Where we have not entered into a contract with you, we base the processing of your Personal Information on our legitimate interest to operate and administer our Services. • Providing necessary functionality: to perform our contract with you for the use of our Services. Where we have not entered into a contract with you, we base the processing of your Personal Information on our legitimate interest to provide the necessary functionality required during your use of our Services. Page 5 of 9 • Developing and improving our services: to analyze trends and to track your usage of and interactions with our Services to the extent it is necessary for our legitimate interest in developing and improving our Services and providing our users with more relevant Service offerings, or where we seek your valid consent. • Assessing and improving user experience: to process device and usage data, which in some cases may be associated with your Personal Information, in order to analyze trends that assess and improve the overall user experience to the extent it is necessary for our legitimate interest in developing and improving the website, or where we seek you valid consent. • Promoting the security of services: by tracking the use of our Services, creating aggregated, non-personal data, verifying accounts and activity, investigating suspicious activity and enforcing our terms and policies, to the extent this is necessary for our legitimate interest in promoting the safety and security of the Services, systems and applications and in protecting our rights and the rights of others. • Managing user registrations: to process your Personal Information by managing your user account, if you have registered for an account with us, for the purpose of performing our service with you according to applicable terms of service. • Handling contact and user support requests: if you fill out a “Contact Me” web form or request customer support, of if you contact us by other means including via email, we process your Personal Information to perform our service with you and to the extent it is necessary for our legitimate interest in fulfilling your requests and communicating with you. • Managing Payments: to verify financial information you provide to us and or collect payments to the extent that doing so is necessary to complete the transaction and perform our service with you. • Sending product communications and other information: to send you product information about changes to our products, upcoming products you may be interested in, and other non-transactional communications about us and our affiliates and partners, including information about our products, promotions or events as necessary for our legitimate interest in conducting direct marketing or to the extent you have provided your prior consent. Provide you with additional information that may be of interest, such as NSLT news and announcements, study tips for students or teacher guides for professionals. • Complying with legal obligations: when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Information to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our websites, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes or to respond to lawful requests. Page 6 of 9 POTENTIAL CUSTOMER • Identifying customer opportunities: to assess new potential customer opportunities to the extent that it is in our legitimate interest to ensure that we are meeting the demands of our customers and their users’ experiences. • Sending marketing communications: to send you marketing information, product recommendations and other non-transactional communications about us and our affiliates and partners, including information about our products, promotions or events as necessary for our legitimate interest in conducting direct marketing or to the extent you have provided your prior consent. Sharing Your Personal Information We may disclose your Personal Information with third parties for the purposes of operating our business, delivering, improving, and customizing our Services, sending marketing and other communications related to our business, and for other legitimate purposes permitted by applicable law or otherwise with your consent. We may share your Personal Information with the following categories of third parties: • With your school and (if you are student) with your instructors if you are affiliated with an educational institution. For example, we provide our institutional clients with reports about how their instructors and students use our products, including information that compares instructors and students within a school. If you are a student, your instructors will have access to all the information generated by your use of the products for a class. We may also provide Personal Information to your school, as needed, to investigate possible academic fraud or cheating. Your school uses your Personal Information in accordance with its own privacy policies. Your Personal Financial Information (Credit Card Numbers, Bank account information, routing numbers) are never shared with your school or learning institution. • With our service providers, who are bound by law or contract to protect your Personal Information and only use your Personal Information in accordance with our instructions. Examples include but are not limited to: processing orders and credit card transactions, assisting with marketing-related efforts, and providing customer support. • In response to a request for information by a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation or legal process. • With law enforcement officials, government authorities, or other third-parties as necessary to comply with legal process or meet national security requirements; protect the rights, property, or safety of NSLT, its business partners, you, or others; or as otherwise required by applicable law. • In aggregated, anonymized, and/or de-identified form which cannot reasonably be used to identify you. • NSLT does not allow any student to see or access any other student’s information in any way. • If we otherwise notify you and you consent to the sharing. Page 7 of 9 Sale of Personal Information NSLT does not sell Personal Information to third parties for any personal, business, or commercial purposes. Social Media Interactions and Interest-based Ads Our websites may enable you to interact with us and others via social media platforms, such as Facebook or Twitter. While we respect each social media platform’s privacy policies, we may collect Personal Information about you and your friends if you choose to use these tools. For example, we may allow you to sign into NSLT websites and applications using Facebook Connect. If you choose to do this, we may collect basic profile information and your profile picture but only if the privacy settings you and your friends set within Facebook allow it. We will use the information to log you into our program. Forums and Other Public Areas Our products do not utilize the use of forums or any public areas. There is not user-to-user interactions and members cannot access any membership directory or member profile information. No member has access to another member’s information in any form. Your Choices and Rights NSLT respects your rights in knowing what Personal Information we have about you and how that information is collected, used and shared. You may request we disclose what Personal Information we have and to access, make corrections to, or delete this Personal Information. You may limit the information you provide to us and also limit the communications that we send to you. These options are accessible from the member profile page. ACCESS, CORRECTION, OR DELETION OF YOUR INFORMATION If you would like to correct or update your Personal Information, or to request access to or deletion of your Personal Information, you may contact us by one of the methods listed in the How to Contact Us section – include your name, email address, account identification, and purpose of the request. If you have an online account, you can log into your account at any time to access and update the information you have provided to us. If you request a change to or deletion of your Personal Information, please note that we may still need to retain certain information for recordkeeping purposes, and/or to complete any transaction that you began prior to requesting such change or deletion (e.g., when you make a purchase, you may not be able to change or delete the Personal Information provided until after the completion of such purchase). Some of your information may also remain within our systems and other records where necessary for compliance with applicable law. NSLT complies with all laws regarding access, correction and deletion of Personal Information. At your request and where the law requires us to do so, we will confirm what Personal Information we hold about you. You may also have a legal right to obtain a copy of your Personal Information. You can make such a request by making a written request in one of the ways described in the How to Contact Us section. We may charge a processing fee for this Page 8 of 9 service where permitted by law and we will require verification of the request and evidence of your identity before fulfilling your request. ADVERTISING AND MARKETING CHOICES We give you many choices regarding our use and disclosure of your Personal Information for advertising and marketing purposes. To opt-out of emails, simply click the link labeled “unsubscribe” at the bottom of any email we send you. Please note that even if you opt-out of product information emails, we may still need to contact you with important information about your account. For example, even if you opt-out of marketing emails, we may still send you login activity or billing confirmations. Finally, you have a right not to receive discriminatory treatment for the exercise of your privacy rights. For California Consumers, you have a right to designate an authorized agent to make a request on your behalf. Retention of Data We will retain your Personal Information for as long as is reasonably needed to accomplish the purpose for which it was collected, as explained in this Privacy Notice, and in accordance with our retention policies. In some circumstances we may store your Personal Information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements. In specific circumstances we may store your Personal Information for longer periods of time so that we have an accurate record of your dealings with us to resolve disputes or enforce agreements. International Transfers Your Personal Information may be transferred to, stored at or processed in the United States and other countries which may not have equivalent privacy or data protection laws. However, regardless of where your Personal Information is transferred, we will protect it in accordance with this Privacy Notice. Information Security We intend to protect the Personal Information entrusted to us and treat it securely in accordance with this Privacy Notice. NSLT implements reasonable technical, physical, and administrative safeguards designed to protect your Personal Information from unauthorized access, use, or disclosure. We also contractually require that our suppliers protect such information from unauthorized access, use, and disclosure. The Internet, however, cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any Personal Information you provide to us. Privacy Policies of Third Parties This Privacy Notice only addresses the use and disclosure of information by NSLT and its affiliates and does not apply to your use of a third party site. Other websites that may be Page 9 of 9 accessible through this website have their own privacy policies and data collection, use and disclosure practices. We encourage you to familiarize yourself with the privacy statements provided by all third parties prior to providing them with information or taking advantage of an offer or promotion. Changes to this Privacy Notice From time to time, we may update this Privacy Notice to reflect new legal requirements or changes to the way we operate our business. We will place a notice online if we make significant changes to this the Privacy Notice. Additionally, if the changes will significantly affect the way we use or disclose previously collected Personal Information, we will notify you about the change by sending a notice to the primary email address associated with your account. How to Contact Us Please contact us if you have any questions or comments about our privacy practices, this Privacy Notice, or if you wish to exercise your rights. We will investigate and attempt to resolve complaints and disputes and will make every reasonable effort to honor your wish to exercise your rights as quickly as possible, and in any event, within the timescales provided by data protection laws. Email: [email protected]. Mail: National Society for Legal Technology, Inc. 12340 Hesby Street Valley Village, CA 91607