Upverter Education

UPVERTER EDUCATION PRIVACY POLICY

              Upverter Education, a division of Upverter, Inc. and a subsidiary of Altium Ltd. (“Upverter”), offers a curriculum and associated educational services through its website at www.education.upverter.com to middle and high school students wishing to learn about the use and design of printed circuit boards (the “Service(s)”).  Upverter understands the importance of protecting the personal information collected from its student users in the operation of our Services and of taking reasonable steps to maintain the security, integrity and privacy of any information in accordance with this Privacy Policy.  This Privacy Policy describes how Upverter collects and uses the personal information its students provide to it when they use the Services as well as how the rights that they, and if under 13, their parents, have in that regard.  In providing the Services Upverter at all times strives and intends to comply with the privacy obligations imposed under the Childrens Online Privacy Protection Act (COPPA) and the Family Educational Rights and Privacy Act (FERPA).  If at any time you believe we have failed to comply with either Act please notify us immediately at [email protected].

Accessing the Services; Parental Consent; and How We Collect Information

When you first access the Service you will be asked to confirm that you are 13 years of age or older. If you are under 13 years of age you will be required to do the following: a) provide Upverter with an email address for one of your parents; b) Upverter will contact your parent and ask if he/she has granted you permission to use the Services; such parent must write back to Upverter providing such email consent.  If no such consent is provided you will not be able to access and use the Services.  If you misrepresent your age as being over 13 Upverter will terminate your use of the Services permanently if it detects the same.

Parents of children under 13, please be aware that we will contact you only to obtain the consent described and such consent shall only be as to the information described in this Privacy Policy.  If you do not consent to such activity by your child s/he will not be permitted access to the Services. If your child uses our Services we will require your child to disclose only such information as is required to properly use the Services.  You can update any such information, ask us to delete it or refuse to allow any further collection of information about your child.  We will also notify you directly in the event that we wish to collect any new categories of information and first obtain your consent to the same regarding your child.  If after contacting you to obtain consent we do not hear from you within a reasonable time we will delete all personal information regarding you and your child.  As also noted parents can require deletion of information about their children under 13 at any time and we will do so although such deletion will bar your child from further use of the Services.

Upverter may collect personal information from its student users in the following ways: (1) directly from written input (such as by registering for the Services and providing the registration information); or (2) automatically through Upverter’s website technologies such as through the use of cookies (which are small text files created by websites that are stored on your computer), by smart devices, by combining data sets, by collecting data from a browser or device for use on a different computer or device, or by using algorithms to analyze a variety of data such as records of purchases, online behavioral data, or location data.  Such collection of data applies regardless of how a user accesses the Service, whether through personal computers, phones, mobile devices or otherwise and applies to any interactive features, plug-ins, widgets and so forth connected to or with the Service. 

Information We May Collect

              The types of personal information that Upverter collects directly from you may include:

• Your name and email address;
• Your age;
• Internet Protocol (“IP”) addresses used to connect your computer to the Internet;
• Tracking codes through the use of cookies;
• Usernames and passwords;
• Comments, feedback, posts, and other content you provide to Upverter in using the Services;
• and
• Communications with other users of Upverter’s Services.

              In addition, Upverter may collect other information about your interaction with the Services that may or may not qualify as personal information, such as the courses you participate in within the Services, the time and date of such use of the Services and suggestions you make to Upverter regarding the Services or how to improve them.  Upverter may also create aggregated, anonymized collections of data regarding users use of the Services that do not reveal the personal information of any student.

How We Use Your Information

              Upverter uses your personal information in specific ways, including the performance of providing you with the Services, to comply with legal obligations, or where Upverter has a legitimate business interest in using your information to enhance the Services or products we provide. Legitimate business purposes include but are not limited to one or all of the following: modifying, improving or expanding our Services, conducting data analytics regarding your use of the Services, detecting fraud; investigating suspicious activity and otherwise keeping our Services safe and secure.  In addition, we may use your information in the following ways (after obtaining your consent, where required):

• To provide you with information about the Services and changes or additions to the Services;
• For internal business purposes in determining how to modify the Services or whether to add other services or products which may be of interest to you;
• To administer the Services and for internal operations, including troubleshooting, data analysis, testing, statistical, and survey purposes;
• To allow you to participate in interactive features of our Services; and
• For any other legitimate business purpose that we may notify you of from time to time.

How Long We Keep Your Personal Information

              We will keep your personal information only so long as is necessary for the purpose for which it was collected. This means that unless information must be retained for legal or archival purposes, personal information will be securely destroyed, put beyond use or erased from Upverter’s systems when it is no longer required or, where applicable, following a request from you to destroy or erase your personal information. Please note that if you request that we destroy or erase all of your personal information you will not be able to make proper use of the Services.  If you have been denied use of the Services because of your age Upverter will delete your name, email and age promptly.

Disclosure And Sharing Of Your Personal Information

              Upverter will never sell your personal information and in relation to California residents, does not do so as defined in the California Consumer Protection Act. Upverter will not disclose to or share your personal information with any unaffiliated third party except as follows:

• Where necessary in connection with services provided by third parties (i) that provide us with a wide range of office, administrative, information technology, data analytics, production, payment, or business management services, and (ii) that are required to comply with this policy;
• Where you provide information and make it available on a public post within the Services;
• Where your consent has been provided by a third party such as your employer, an academic institution, school, business, or other entity that has provided you with access to our Services;
• Upverter hosts its Service through Amazon; as such, your personal information will be shared with Amazon and Amazon’s own privacy and other policies may apply to such storage and hosting;
• Where Upverter is required to disclose personal information in response to lawful requests by public authorities and government agencies, including to meet national security or law enforcement requirements; to comply with a subpoena or other legal process; when we believe in good faith that disclosure is necessary to protect our rights, to enforce our Terms of Use, or to protect the rights, property, or safety of our Service, users, or others; and to investigate fraud; and
• Where all or substantially all of the business or assets of Upverter relating to the Services are sold, assigned, or transferred to another entity.

Cross-border transfers

              Upverter may transfer your personal information and any intellectual property you submit in connection with the Services outside of your country of residence for the following reasons:

• In order to process your transactions involving the Services we may store your personal information on our servers, and those servers may reside outside the country where you live. Upverter has servers and major office locations in several countries, including the United States.  Such processing may include, among other things, the fulfillment of your order, the processing of your payment details, and the provision of support services; and
• In order to satisfy global reporting requirements Upverter may be required to provide your personal information to Upverter affiliates or subsidiaries in other countries.

              By submitting your personal information, you agree to this transfer, storing, or processing of your information outside of your home country. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy and all applicable data protection laws.

Security

              We will use appropriate physical, technical, and administrative safeguards to protect your data. Access to your personal data will be restricted to only those who require that information to perform their job function. In addition, we train our employees about the importance of maintaining the confidentiality and security of your information.

Cookies

              Through the use of cookies, small files maintained on your computer when you log into the Services, we gather certain information automatically. This information may include IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site.  Upverter and its partners use cookies or similar technologies to analyze trends, administer the Services, track users’ movements around the Service, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions in our Service.

Your Rights

              You (and if you are under 13, your parents) have the right to make a written request to be informed whether or not we hold or process any of your personal information (by emailing [email protected]). In your written request, you may:

• Ask that we provide you with details of your personal information that we process, the purpose for which it is processed, the recipients of such information, the existence of any automated decision-making involving your personal information, and what transfer safeguards we have in place;
• Request that we rectify any errors in your personal information;
• Request that we delete your personal information if our continued processing of such information is not justified;
• Request that we transfer your personal information to a third party;
• Object to automated decision-making and profiling based on legitimate interests or the performance of a task in the public interest (in which event the processing will cease except where there are compelling legitimate grounds, such as when the processing is necessary for the performance of a contract between us); and
• Object to direct marketing from us.

              Where applicable under your local laws, we will not use your personal information for marketing purposes, nor disclose your information to any third parties unless we have your prior consent, which we will seek before collecting your personal information. You can exercise your right to prevent such processing by checking certain boxes on the consent forms we use when collecting your personal information.  If at any point you wish to review or change your preferences you can use the “opt-out” or unsubscribe mechanism or other means provided within the communications that you receive from us or by sending an email to [email protected]. Note that you may still receive transactional communications from Upverter.

Third parties

              Upverter’s Services may include links to third-party websites or services. In using such links, please be aware that each third-party website is subject to its own privacy and data protection policies and is not covered by our Privacy Policy. In addition, we may allow third-party companies to serve ads and/or collect certain anonymous information when you visit our websites. These companies may be placing and reading cookies in the cookie file of the browser on your computer’s hard disk or using web beacons or other technologies to collect information in the course of ads being served on this website. These companies may use information other than personal information (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to these and other websites in order to provide advertisements about goods and services likely to be of greater interest to you.

Changes to this Privacy Policy

              Please note that Upverter’s Privacy Policy is reviewed periodically. Upverter reserves the right to modify its Privacy Policy at any time without notice. Any changes to the Privacy Policy will be posted on this page and will become effective on the date of posting. We encourage you to periodically review this page for the latest information on our privacy practices.

Recourse

              Any comments, complaints, or questions concerning this policy or complaints or objections about our use of your personal information should be addressed by directing your comments to Upverter’s Data Protection Officers, by contacting [email protected]. In relation to personal data processed within the United States, Upverter has in place EU Model Clauses between entities within its group of companies that receive and process personal information from countries within the European Economic Area.