Merlyn Mind Privacy Policies

Product Privacy Policy

This applies to use of our solutions, including Teacher Portal, Management Console, and applications.

Please find the Privacy Policy document here https://cdn.merlyn.org/terms/privacy-policy.pdf

Website Privacy Policy

This applies to our marketing site https://www.merlyn.org and https://www.merlynmind.ai only.

Updated and Effective 06/21/2021

This Privacy Policy applies to the website available at https://merlyn.org/ and https://www.merlynmind.ai (the “Website”) owned and operated by Merlyn Mind (“Merlyn Mind,” “we,” “us,” and “our”). It does not apply to the Merlyn digital assistant, including the web-based portal, which are governed by a separate privacy policy. This Privacy Policy describes how we may collect, use, and disclose information that identifies, describes, or relates to an identified or identifiable individual, or information that is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household (“Personal Information”) from visitors to our Website (“you,” “your”). It also describes your choices regarding use, access, and changes to your Personal Information.By accessing or using the Merlyn Mind Website, you acknowledge that you have read and understood this Privacy Policy. In addition to reviewing this Privacy Policy, please also review our Terms of Use, because that forms an agreement between you and us.In addition to reviewing this Privacy Policy, please also review our Terms of Use, because that forms an agreement between you and us.

Contents

• Information We Collect


o Note About Children


o Usage Information and Cookies

o Third Party Cookies and Tracking

• How We Use and Disclose Your Personal Information

• How you May Modify Your Information


• Third Parties

• Links

• Security

• Data Retention

• Opt-Out Policy

• Additional Information for EEA Residents

• Updates to This Policy

• Contact

Information We Collect

If you request information about our education products or ask a question of our customer support team, we will ask you to provide certain Personal Information so that we may respond to your request. For example, if you choose to sign up to receive resource updates, we will ask you to provide your first and last name, email address, business or organization name, your role, and the reason that you are contacting us.

A Note About Children

Our Website is intended for a general audience, and not for individuals under the age of 13 or otherwise under the age of consent in each region in which we operate (“children,” “child”). We do not knowingly collect Personal Information from children through our Website. Should we learn that we have inadvertently collected Personal Information from a child through our Website, we will take steps to promptly delete it.

Usage Information and Cookies

As with most companies, when a you access our Website, our servers automatically collect the Internet Protocol (“IP”) address associated with your computer. We may also collect additional information such as a device ID, browser type and version, the operating system of your device and language, country, as well as areas of the Website you visit most frequently and when. This information is used to help us administer the Website, remember your preferences, and diagnose technical problems. We also analyze the information for aggregate trends about how our Website is used and to help improve our Website. To collect this information, we use cookies. Cookies are small data files sent by a website and stored on the computer or device at the request of that site. Cookies store information related to a user's browser to enable us to recognize the browser on return visits to our Website and to remember your preferences.

Third Party Cookies and Tracking

We use third-party service providers to assist us in collecting and understanding usage information. Most browsers can be set to detect browser cookies and to let a user reject them, but refusing cookies may affect the usability of our Website. A list of companies that use cookies on our Website, the services they provide, and information on how you may opt out of certain cookies is included in our Cookie Notice. To learn more about browser cookies, including how to manage or delete them, refer to the “Tools,” “Help,” or similar section of your web browser. We do not serve targeted advertising on our Website, and we do not track your activity across different websites or online services. However, when you use the Internet, unaffiliated third parties such as ad networks, web analytics companies and social networking platforms may collect information about your online activities over time and across our and other websites. This information may be used to provide advertisements for products and services that may interest you, and those companies may use cookies, clear GIFs and other tracking technologies. As with most sites, we do not honor “do not track” signals transmitted by web browsers as there is no industry standard for implementing such programs.For more information about third-party advertisers and how to prevent them from using your information, visit http://www.networkadvertising.org/choices, http://www.aboutads.info/choices/, or http://www.youronlinechoices.com/uk/. If you do want to opt out using these tools, you will need to opt out separately for each of your devices and for each web browser (such as Chrome, Edge Firefox, Safari or others) that you use on each device.

How We Use and Disclose Your Personal Information

We do not access or disclose your personal information except as noted at the time that we request it, or as listed below

To administer our Website: to maintain and administer our Website to ensure service quality, and to ensure the security of our Website, including providing support, services and security through our third party providers.

To communicate with you: including to respond to your requests, resolve a support issue, notify you about changes to the Website, and to otherwise communicate and solicit feedback from you.

In the event of a reorganization, merger, sale, assignment, bankruptcy, or similar business change: we may need to transfer your Personal Information to that re-organized entity or new owner after the sale or reorganization for them to use in accordance with this Privacy Policy.For EU residents, our legal basis for these practices is fulfillment of our legitimate interests, to enable us to perform our obligations and provide you with access to our Website, and to change our business.

In relation to a known or suspected violation of our terms of use, fraud prevention or other unlawful use: including to share Personal Information with entities assisting us with an investigation or as may be required by applicable law.

In connection with legal or regulatory obligations: We may use and disclose your Personal Information as necessary to protect our rights or the rights and safety of our users, or as necessary in the event of a court order, regulatory inquiry or other lawful request. Provided, however, that unless legally prohibited, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.For EU residents, our legal bases for these practices are to fulfill our legal obligations and legitimate interests, such as to allow us to ensure the legality of our Website and to cooperate with law enforcement and regulatory authorities.

To provide you with marketing materials: to provide you with updates and offers about our products. At any time, you may unsubscribe or opt-out of further communication on any electronic marketing communication by using the link labeled “unsubscribe” available in each email communication or by contacting us at privacy@merlyn.org.For EU residents, our legal basis for these practices is your consent.

How You May Modify Your Information

If you would like to review, correct, update or request that we delete Personal Information you have provided to us, please contact us at privacy@merlyn.org and specify what you would like to review, correct, update or have deleted.

Third Parties

We may engage with third parties to facilitate delivery of our Website and to provide certain features on our behalf, such as data hosting, analytics, content delivery, maintenance, email and marketing management, security and similar functions. These third parties may require a limited amount of information, including Personal Information, in order to deliver their services. We may also share aggregated demographic information that is not linked or linkable to Personal Information with our partners.

Links

Our Website contains links to third party websites, including social networking websites. The fact that we link to a website is not an endorsement or representation of an affiliation with that website. We do not control third party websites or their privacy practices. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other sites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of all the websites you visit.

Security

We are committed to protecting the confidentiality, integrity and availability of your personal information through the use of physical, administrative, and technical safeguards. The Internet, however, is not perfectly secure and we are not responsible for security breaches not reasonably within our control.

Data Retention

We retain Personal Information for as long as is necessary to provide you with access to our Website or for as long as is permitted under applicable laws, including as necessary to comply with our legal obligations, resolve disputes, enforce our agreements, comply with applicable industry standards, and protect the security of our Website.

Opt-Out Policy

We may send you emails with information about our products that we believe may be of interest. You may out of receiving these email messages from us by clicking on the “unsubscribe” link found at the bottom of every email that we send or by contacting us at privacy@merlyn.org. We do not send email messages on behalf of third parties.

California “Shine the Light” Rights

If you are a resident of California, you may request certain information regarding our disclosure of Personal Information (if any) for marketing purposes. To make such a request, please contact us at: Merlyn Mind, 405 Lexington Avenue, Suite 3504, NY, NY – 10174.

Additional Information for EEA Residents

When you access our Website, we function as a “data controller” under the General Data Protection Regulation (“GDPR”). In some cases, we will ask for your consent so that we may process your personal information. In other circumstances, we may rely on a different lawful basis, as explained in the section, “How we Use and Disclose Your Personal Information.” If you are located outside of the United States, please be aware that your information will be transferred to, processed and stored in the United States. By submitting your Personal Information, you acknowledge that we may transfer, process and store your information in this way. Wherever the information is, it will be treated securely and in accordance with this Privacy Policy and applicable privacy laws of the United States. These laws may be different from the privacy laws in your country. However, this does not change our commitments to safeguard your privacy, and we will comply with all applicable laws relating to the cross-border data disclosure of your Personal Information. Where required, we will implement Standard Contractual Clauses with our third parties or rely on such other transfer mechanism to ensure that the transfer of your Personal Information outside of the EEA is lawful. You may request details of the transfer mechanisms that we rely on to transfer Personal Information outside of the EEA by emailing us at privacy@merlyn.org. Additional Data RightsPlease note that the rules in your country may provide you with additional rights or may limit these rights. In all cases, our provision of the rights will comply with the applicable laws. If you are based in the EEA, for example, you may have the right to access, update or correct your Personal Information, to request deletion of your Personal Information, to object to certain processing, including that related to marketing, to receive a machine-readable copy of the Personal Information about you that you provided to us, and, in certain circumstances, to request that we transfer that Personal Information to an applicable third party. In addition, where you provided your consent for our processing of your Personal Information, you may withdraw your consent by contacting us using the details provided in the “Contact” section. You may also restrict how we use your Personal Information while a complaint is being investigated. Your exercise of these rights is subject to certain exemptions to safeguard the public interest (for example, the prevention or detection of crime) and our interests (for example, the maintenance of legal privilege). If you contact us to exercise any of these rights, we will verify your request and respond within thirty days.

Updates to This Privacy Policy

As our Website evolves, we may make changes to this Privacy Policy. We will alert you to changes by providing notice within the Website or otherwise as required by law. The “last updated” note at the top of this policy indicates when it was last revised, and updates will become effective when they are posted.

Contact

If you have any concerns or complaints about how we handle your personal information, or if you have questions regarding this Privacy Policy, please contact us at:

8 West 40th Street, 20th Floor, NY, NY 10018

privacy@merlyn.org

If you have concerns or complaints regarding this Privacy Policy or our data handling procedures, you may have a right to lodge a complaint with a supervisory authority.