Last updated: Aug 10, 2020
LifeAt, LLC is a technology and service company partnering with education leaders to mitigate multifaceted and complex problems facing students and universities, colleges, community colleges, graduate programs, K-12 schools, and independent schools. We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at contact@lifeat.org
This privacy policy (“Privacy Policy”) describes the gathering of personal information by LifeAt, LLC. (“Company,” “we,” “us”, or “our”) from users (“you”, “your”) and our clients (“colleges”, ”universities”, “Community colleges”, “Graduate programs”, “K-12 schools”, and “Independent schools”) when using the service provided through our internet based website lifeat.org via mobile or desktop.
Privacy Commitment
LifeAt is fully committed to maintaining the privacy and the security of confidential and sensitive information we may collect, process, and house, which is voluntarily provided to us directly by our clients and users.
Contacting us
If you have any questions or comments about this Privacy Policy, you may contact us by email at contact@lifeat.org or by mail at:
LifeAt, LLC.
12224 BEL-RED ROAD #249
Bellevue, WA, 98009-2207
USA
What information do we collect?
Personal information you disclose to us
In Short:LifeAt LLC collects personal information that users or clients provide to us such as name, address, contact information.
We collect personal information that you voluntarily provide to us when registering at the Services expressing an interest in obtaining information about us or our products and services, when participating in activities on the Services (such as posting messages in our online forums or entering competitions, contests or giveaways) or otherwise contacting us.
The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The personal information we collect can include the following:
Name and Contact Data. We collect your first and last name, email address, postal address, phone number, and other similar contact data as part of our user registration flow.
Credentials. We will be using Google Cloud to encrypt passwords, password hints, and similar security information used for authentication and account access. LifeAt will not have the ability to see this information.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short:Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our Services.
We will work with Education institution (“client”) partners to decide how your personal information is used. We provide nearly all of our products and services to end users of an institution as a “data processor” on behalf of our clients (e.g., colleges, universities, and school districts). This means that when your data is collected by our clients and given to LifeAt, the main responsibility for data privacy compliance lies with your institution as a “data controller.” It also means that your institution’s privacy policy governs the use of your personal information (rather than ours). If collected through our system, LifeAt will determine what information we collect through our products and services and how it is used, and we process your information according to explicit safety precautions.
We automatically collect certain information when you visit, use or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
Information from other sources
We may receive information about you, including personal information, from third parties, and may combine this information with other personal information we maintain about you. If we do so, this Privacy Policy governs any combined information that we maintain in a personally-identifiable format.
Cookies and similar technologies
Cookies are small files that are stored on your computer or mobile devices by saving your information such as user ID and other preferences. Cookies are either deleted from your computer or mobile device at the end of every session or are maintained for a longer period of time. As a result, we use cookies to distinguish you from other users of our Service and this helps us to provide you with a personalized experience when you use the Services, and also allows us to better understand how you use the Services. For example, we use cookies to keep you logged in to LifeAt LLC and to protect your account. We also use cookies for analytical purposes to better understand how you use the Services and to deliver the best user experience.
How do we use personal information?
In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
Request Feedback. We may use your information to request feedback and to contact you about your use of our Services.
To deliver services to the user. We may use your information to provide you with the requested service.
URL, IP addresses, Device Information and Frequency of Use. We use this personal information to better understand how frequently you use the Services, the time you spend actively using the Services, and the pattern of actions you take in using the Services, We also track the URL that you visited before you came to our Services, the URL to which you next go to, information about the browser through which you are accessing the Services, and your Internet Protocol (IP) address. We use this information to administer and improve our Services, help diagnose problems with our Services, and to better understand your use of the Services. Your IP address may also be used to help identify you and to gather broad location and demographic information.
Location data. We use location data to autofill the address of a location being scanned when using the Service. We also use location data to assist the processing of image data and to better understand how multiple scan locations are related to each other. We also use location data to provide aggregated analytics to better understand how and where the Service is being used, to provide a customized and localized experience when using the Service, and to prevent access to the Services where required by law.
Online Inquiries and Correspondence. We use the personal information you provide so we may communicate with you regarding your inquiry and to satisfy other requests. If you provide your phone number, we may use that information to make direct dial calls, autodialed and prerecorded message calls, and to send text messages, from LifeAt LLC relating to our products and services. If you correspond with us via email or by written mail, we may store the information you submit in a manner specific to you, for example in an electronic file indicating you are the sender.
For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.
When do we share your personal information?
In Short: LifeAt LLC will not share, rent, sell or otherwise disclose any of the personal information that we collect about you, except when we have your permission or in any of the following situations:
Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
Marketing Interests: We may disclose the results of aggregated data about you for marketing or promotional purposes, as further described below. We may disclose, to the owners of certain content available through the Services, or their representatives, the following types of aggregated data about usage of such content: the number of views and the number of users who view the content, statistical information about users who view the content by geography, the referring URLs of users who view the content, the number of users who interacted with the content in specific ways, and other similar aggregated information relating to usage of the content.
Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data about how you interact with the Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the Services. These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.
Other Users. When you share personal information (for example, by posting comments, contributions or other content to the Services) or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly distributed outside the Services in perpetuity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.
Direct marketing
From time to time, we may contact you with information about our products and services. Most marketing messages we send will be by email. For some marketing messages, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you. In most cases our processing of your personal data for marketing purposes is based on our legitimate interest to provide you information about our current and future products, services and events.
If you do not want to receive marketing messages from us, you will be able to tell us by selecting certain boxes on forms we use when we first collect your contact details. If you receive marketing email from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt-out from receiving marketing email from us, and any other promotional communications that we may send to you from time to time (e.g., by postal mail) by sending your request to us by email at contact@lifeat.org or by writing to us at the address given in the ‘Contacting us’ section of this Privacy Policy.
Please be aware that if you opt-out of receiving marketing email from us, it may take up to ten business days for us to process your opt-out request, and you may receive marketing email from us during that period. Additionally, even after you opt-out from receiving marketing messages from us, you will continue to receive administrative and transactional messages from us regarding your use of the Service.
How do we use online analytics services and tailored online marketing?
Online and interest-based advertising. At this time we do not use third-party advertising tools to collect information about your visits to our websites to serve you targeted advertisements based on your browsing history and interests on other websites and online services or on other devices you may use.
Google Analytics and Advertising. We may utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to our websites. We may also merge data from Google Analytics with data from other EAB’s databases to personalize your experience on our website. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://adssettings.google.com.
California privacy disclosures
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Sec. 1798.100 et seq., also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from our systems.
The following California privacy disclosures supplement the information contained in this Privacy Policy and apply solely to individual residents of the State of California (“California Residents” or “consumers” or “you”). When you use the Services, we collect personal information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your device.
Personal information does not include information publicly available from government records, de-identified or aggregated consumer information, information relating to our employees, contractors, and other personnel, and information excluded from the CCPA’s scope such as personal information covered by certain sector-specific privacy laws such as the Health Insurance Portability and Accountability Act of 1996 (HIPAA), the California Confidentiality of Medical Information Act (CMIA), the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
Personal information collected via:
- Directly from you, for example when you sign up for the Service.
- Indirectly from you, for example by observing or analyzing your use of the Service via our websites and mobile applications.
Please review the section ‘What information do we collect?’ in this Privacy Policy for more information regarding the specific personal information we collect.
Use of personal information for California Residents
Please review the section ‘How do we use personal information?’ in this Privacy Policy for the ways we may use or disclose the personal information of California Residents.
Sharing personal information for California Residents
We do not “sell” personal information as most people would typically understand that term. However, we do allow certain education partners and providers to collect information about consumers directly through our services for purposes of analyzing and optimizing our services, providing content and ads that are more relevant, measuring statistics and the success of ad campaigns.
EU privacy rights
If you are located in the EU, you have the following rights in respect of your personal data that we hold:
- Right of access. You have the right to access the personal information that we hold about you.
- Right to rectification.You may have the right to require us to correct any inaccurate or incomplete personal information we hold about you.
- Right to be forgotten. In certain circumstances you may have the right to the erasure of your personal data we hold about you (for example where it is no longer necessary in relation to the purposes for which it was collected or processed).
- Right to restriction. You may have the right to request that we restrict processing of you personal information in certain circumstances (for example where the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of that personal data).
- Right to portability. In some limited circumstances, you may have the right to portability which allows you to move, copy or transfer personal data from one organization to another.
- Right to object.You have a right to object to us processing your personal information when the processing is based on legitimate interests and also to stop us sending you direct marketing.
- Rights in relation to automated decision making and profiling. You have the right not to be subject to a decision that affects you based solely on automated processing. See the section ‘Automated Decision-making’ in this Privacy Policy for more information.
If you wish to exercise one of these rights, please contact us using the information in the ‘Contacting us’ section of this Privacy Policy.
Do we make updates to this policy?
In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.
We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.
What is our policy on children users of the Services?
LifeAt’s products and services are not intended for children under the age of 13, and we do not knowingly collect any information from children. If we learn that we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information upon request. If you are a parent or guardian and discover that your child under the age of 13 has obtained an account on the Services or otherwise provided us with personal information without your consent, then you may alert LifeAt atcontact@lifeat.organd request that we delete that child’s personal information from our systems.