PRIVACY POLICY

Last updated version: July 6, 2017

Introduction

The following Privacy Policy accessed through our website explains how we treat information you provide.

This Privacy Policy governs information collection, usage and disclosure. Describes our practices in connection with information that we collect through the websites (the “Websites), the software applications made available by us for use on or through computers and mobile devices (the “Apps”) and HTML-formatted email messages that we send and that link to this Privacy Policy, all owned by Progrentis Corp. (“Progrentis”, “we” or “us”) and from which you are accessing this document. We refer to such websites, apps and emails in this agreement as the “Services.” Our Privacy Policy applies to users who are authorized to access the password-protected areas of the Services (“Authorized Users”).

By providing Personal Information to us, you agree to the terms and conditions, without modification, of this Privacy Policy that governs information collection and usage. If you don ́t agree with the terms of this Privacy Policy, you may not access or use the Services.

Personal Information

We do not collect any Personal Information directly from children under 13 years of age. As described in more detail below, we may collect, use and disclose Personal Information from older users.

Personal Information” is information that identifies an accountholder as an individual or relates to an identifiable person, including but not limited to: e-mail address, name, home or work address or telephone number.

If you submit any Personal Information relating to other people (including children under 13 years of age) to us or to our Service Providers (third party or outsourced suppliers) in connection with the Services, you represent that you have the authority to do so and to allow us to use the information in accordance with this Privacy Policy.

How We May Collect Personal Information

We and our Service Providers may collect Personal Information from accountholders in a variety of ways, including:

  • Through the Services: We may collect Personal Information through the Services, e.g., when you create an account or populate your profile.

  • Offline: We may collect Personal Information from you offline, such as when you contact customer service.

  • From Other Sources: We may receive your Personal Information from other sources, such as public databases, joint marketing partners and other third parties.

    Please keep in mind that if you directly disclose personally identifiable information or sensitive personal data through our public message boards, this information may be collected and used by others.

How We May Use Personal Information

We do not sell any personal information. We may use Personal Information collected from accountholders:

  • To operate the Services you have requested.

  • To respond to your inquiries and fulfill your requests, such as to send you newsletters and status reports.

  • To send administrative information to you, such as information regarding the Services and changes to our terms, conditions and policies.

  • To inform you of other products or services available.

  • To contact you via surveys to conduct research about your opinion of current services or of potential

    new services that may be offered.

  • To allow you to participate in contests.

  • To personalize your experience on the Services by presenting customized content and advertising.

  • For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.

  • We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique personally identifiable information (e-mail, name, address, telephone number) is not transferred to the third party.

  • As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

How Personal Information May Be Disclosed

  • To our Service Providers who provide services such as website hosting, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing and other services.

  • By you, on profile pages and other services to which you are able to post information and materials. Please note that any information you post or disclose through these services will become public and may be available to other users and the general public. We urge you to be very careful when deciding to disclose any information on the Services.

  • To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

  • As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

Other Information

Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as:

  • Hardware and software information including browser, device information, IP address and access times.

  • Services usage data such as rates (indexes) of progress, grades and access times logs.

  • Information collected through cookies, pixel tags and other technologies.

  • Demographic information such as country, ZIP code, age, gender and other information provided by you.

  • Institution contact information such as name, email, address, telephone, website, logo and coordinator ́s name, telephone and email.

  • Aggregated information such as answers to all the activities related to the Services.

How We May Collect Other Information
We and our Service Providers may collect Other Information in a variety of ways, including:

Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.

Through your use of the App: When you download and use the App, we and our Service Providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information has been downloaded to the App based on your device number.

Using cookies: Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other anonymous traffic data. We and our Service Providers use the information only to support the internal operations of the Services, such as for security purposes, to facilitate navigation, to display information more effectively, to personalize your experience while using the Services and to recognize your computer in order to assist your use of the Services. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions regarding them.

If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services. For example, we may not be able to recognize your computer, and you may need to log in every time you visit our Website.

Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Services to, among other things, track the actions of users of the Services (including accountholders that may receive emails from us), measure the success of marketing campaigns and compile statistics about usage of the Services and response rates.

Analytics: We use third parties, including Google Analytics, which use cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. You can learn about Google’s practices by going to www.google.com/policies/privacy/ partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on at https://tools.google.com/dlpage/gaoptout.

IP Address: Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for the purposes of providing support for the internal operations of the Services, such as calculating usage levels, diagnosing server problems, and administering the Services. We may also derive your approximate, general, location from your IP address.

From you: Information such as your communications preference may be collected from accountholders when they voluntarily provide it.

By aggregating information: Aggregated Personal Information does not personally identify you or any other user of the Services.

How We May Use and Disclose Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

Third Party Services

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Twitter, Apple, Google, Microsoft, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to these or other organizations.

Security

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. We employ security measures such as using firewalls to protect against intruders, building redundancies throughout our networks and testing for and protecting against network vulnerabilities. When personal information is transmitted to other Web sites, it is protected through the use of HTTPS encryption, such as the Secure Socket Layer (SSL) protocol. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contacting Us” section below.

Choices and Access

Your choices regarding our use and disclosure of your Personal Information

We give accountholders choices regarding our use and disclosure of their Personal Information for marketing purposes. You may opt-out from receiving status & marketing-related emails and notifications from us on a going-forward basis by clicking the unsubscribe link in any such email. In addition, in your user settings, you may opt-out of receiving notifications.

We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving status & marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.

How you can access, change or suppress your Personal Information

If you are an accountholder and you would like to review, correct, update, suppress or delete Personal Information that you have previously provided to us of yourself or others, simply log into the Services and update your profile or notify us in accordance with the “Contacting Us” section below.

In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your requests as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.

Retention Period

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

Cross-border transfer

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage Service Providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, which may have data protection rules that are different from those of your country.

Sensitive information

We ask that you do not send us, and you do not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.

Updates to this Privacy Policy

We may change this Privacy Policy. The “LAST UPDATED” legend at the top indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services. Your use of the Services following these changes means that you accept the revised Privacy Policy.

Contacting Us

If you have any questions about this Privacy Policy, please contact us at privacy@progrentis.com. Because email communications are not always secure, please do not include sensitive information in your emails to us.