Thank you for joining DouSpen. We at DouSpen (“DouSpen”, “we”, “us”) respect customer privacy and want you to understand how we will collect, use and share data about you. This Privacy Policy describes our data collection practices and your rights with respect to personal data.

Unless we link to another policy or indicate otherwise, this Privacy Policy applies when you visit and use DouSpen’s websites, mobile applications, APIs or related services (“Services”). It also applies to potential customers of our corporate and business products.

By using the Services, you agree to the terms of this Privacy Policy. You must not use the Services unless you agree to this Privacy Policy or any other agreement that governs your use of the Services.

What data we collect

We collect certain data directly from you, such as data you share with us, data about your content research and data from third-party platforms that you link to DouSpen. We also collect some data automatically, such as information about your device and which of our Services you interact with or use. All data listed in this section is subject to the following processing activities: collection, recording, structuring, storage, modification, extraction, encryption, pseudonymization, deletion, merging and transfer.

1.1 The data you provide to us

We may collect different data about you depending on how you use the Services. Here are some examples to help you better understand what data we collect.

When you create an account and use the Services (including through a third-party platform), we collect any data you provide to us directly, including:

• Category of Personal Data
• Description
• Legal basis for processing
• Account information
• To use certain features (such as access to materials), you must create a user account, for which we need to collect and store your email address, password, and account settings.
• To create a faculty account, we collect and store information about your email address, name, password, and account settings.
• When using certain features of the website, you will be asked to provide additional information such as occupation, ID number, photo to verify, date of birth, race/ethnicity, special skills and interests, and phone number.
• Once your account is created, you will be assigned a unique identification number.

Publicly Available Materials

Some Services allow you to communicate with other users or share materials publicly, including by downloading courses and other educational materials, posting reviews of materials, posting questions or answers to questions, sending messages to students or faculty, or posting photos or other materials you have uploaded. Such publicly available materials may be available for others to view, depending on where they have been published.

Learning Data

• When you access materials, we collect certain data, including which courses, assignments, labs, workspaces, and tests you have started and completed;
• content and subscription purchases and credits; subscriptions; certificates of completion;
• Your interactions with instructors, teaching assistants, and other students;
• and essays, answers to questions, and other items provided to satisfy course requirements and related materials.

Student payment information

If you make purchases, we collect certain information about your purchase (such as your name, billing address, and zip code) necessary to process your order, which can be saved for future orders if you wish. You must provide certain payment and billing information directly to our payment service providers, including your name, credit card information, billing address and zip code. We may also receive some information from our payment service providers, such as when you have a new card and the last four digits of that card to facilitate payments. For security purposes, DouSpen does not collect or store sensitive cardholder information, such as full credit card numbers or card authentication information.

Data about your accounts on other services

We may obtain certain information through your social media accounts or other online accounts if they are connected to your DouSpen account. If you access DouSpen through Facebook or another third-party platform or service, we ask for your permission to access certain information about that other account. For example, depending on the platform or service, we may collect information about your name, profile picture, account identification number, login email address, location, physical location of your access devices, gender identity, date of birth and friend or contact list.

These platforms and services provide us with information through APIs. What information we receive depends on what information you (through your privacy settings) or the platform or service chooses to share with us.

If you use our Services through a third-party platform or service or click on any third-party link, the collection, use and distribution of your information will also be subject to the privacy policies and other agreements of such third parties.

Communications and Support

If you contact us for support or report a problem or concern (whether or not you already have an account created), we collect and store your contact information, messages and other data about you, such as your name, email address, messages, location, DouSpen user ID, return transaction number and any other data that you provide to us or that we obtain through automated means (which we discuss below). We use this data to answer and address your question or concern in accordance with this Privacy Policy.

We store the above data and link it to your account.

1.2 Data We Collect By Automated Means

When you access the Services (including when you view our materials), we collect certain data through automated means, including:

• Category of Personal Data
• Description
• Legal basis for processing
• System data
• Technical data about your computer or device, such as your IP address, device type, operating system type and version, unique device identifier, browser, browser language, domain and other system data, and platform type.

Usage data

Usage statistics for the Services section, including content studied, time spent on pages or Services, pages visited, features used, search terms, clickstream data, date and time, referrer, and other usage data for the Services section.

Legitimate interests (user interface improvements, fraud prevention and security, regulatory compliance)

The data listed above is collected through server logs and tracking technologies as described in the “Cookies and Data Collection Tools” section below. We store this data and link it to your account.

1.3 Third Party Data.

If you are a current or potential corporate customer of DouSpen, in addition to the data you provide, we may collect certain contact information about the company from third-party commercial sources.

How we collect data about you

We use tools such as cookies, web beacons and similar data collection tools listed above. Some of these tools allow you to opt out of data collection.

2.1 Cookies and Data Collection Tools

We use cookies, which are small text files that are stored by your browser and may be used to collect, store and share data about your activities on websites, including the DouSpen website. Cookies also allow us to remember information about your visits to DouSpen, such as your preferred language preference, and to make the site easier to use.

2.2 What we use the Data Collection Tools for

DouSpen uses the following kinds of Data Collection Tools for the purposes described below:

• Strictly necessary: these Data Collection Tools allow you to access the site, provide a set of basic functions (such as logging in and accessing materials), provide site security and protection against fraudulent logins, and detect and prevent improper or unauthorized use of your account. These tools are essential to the proper operation of the Services section, so if you disable them, some parts of the site will stop working or become inaccessible.
• Functionality: These Data Collection Tools remember data about your browser and your preferences, enable additional site features, customize the display of content that best suits you, and remember settings that affect the appearance and behavior of the Services section (such as your preferred language or volume level when playing videos).
• Performance: These Data Collection Tools help you evaluate and improve the Services section by providing data on usage and performance, number of visits, traffic sources, or the resource from which the app was downloaded. These tools allow you to test different versions of DouSpen to determine the features and content users prefer and the emails opened.
• Advertising: these Data Collection Tools are used to display relevant advertisements (on our site and/or other sites) according to the usage and system data collected (as described in Section 1) and with information collected about you by advertising providers. The ads displayed may be tailored according to your recent or historical activity on other sites and services. To display targeted ads, we may provide service providers with a hashed, anonymized version of your email address (in human-readable form) and materials that you have shared through the Services.
• Social Media: These Data Collection Tools provide social media features, such as sharing content with friends or networks. These cookies may track a user’s or device’s activity on other sites in order to profile a user’s interests and display targeted advertisements.

You can set your web browser to alert you when cookies are placed on your computer, limit the types of cookies you allow, or refuse cookies altogether. If you refuse cookies, you may not be able to use some or all of the features of the Services and your navigation will change or become less functional. To learn more about managing

How we use your information

We use your data to provide our Services, communicate with you, troubleshoot problems, protect against fraud and abuse, improve and update our Services, analyze use of our Services, provide personalized advertising, and for other purposes required by law or necessary to ensure security and integrity. We retain your data for as long as that data is necessary for the purposes for which it was collected.

We use data collected through your use of the Services for the following purposes:

• Providing and administering the Services, including facilitating the completion of educational material, issuing certificates of completion, personalized display of content, and facilitating interactions with other users (Account Data, Publicly Available Materials, Learning Data, System Data, Usage Data, Approximate Geographic Location);
• Processing payments to instructors and other third parties (Student Payment Data, Instructor Payment Data);
• Processing your requests and orders for educational materials, goods, certain services, information, or features (Account Data, Learning Data, Student Payment Data, System Data, Messages, and Support);

Interacting with you about your account (Account Data, Publicly Available Materials, Learning Data, Raffles, Promotions and Surveys, System Data, Messages and Supports):

• Responding to your questions or concerns;
• Sending you administrative messages and information, including comments from faculty, students, or teaching assistants, notifications of changes to the Services, and updates to our agreements;
• informing you or sending you messages, such as emails or text messages, about your progress in taking courses and with information about relevant materials, bonus programs, new services and opportunities, promotions, newsletters, and other available materials from faculty (which you can opt out of at any time);
• sending push notifications of updates and other relevant messages to your wireless device (you can manage notifications on the mobile app “options” or “settings” pages);
• Manage account and account settings and personalization (Account Data, Learning Data, Student Payment Data, Instructor Payment Data, System Data, Usage Data, Cookie Data);
• Facilitating the technical functioning of the Services section, including troubleshooting and problem solving, security, and fraud and abuse prevention (Account Data, Student Payment Data, Faculty Payment Data, Messaging and Support, System Data, Approximate Geographic Location);
• Verifying instructor identity (Account Data; Instructor Payment Data);
• Receiving feedback from users (Account Data, Messages and Support);
• Market Products, Services, Surveys and Promotions (Account Data, Instructional Data, Raffles, Promotions and Surveys, Usage Data, Cookie Data);
• Commercial subscription plans for prospective customers (Account Data, Training Data, Cookie Data);
• Obtaining more detailed information about you by linking your data to additional data from third-party data providers and/or analyzing data through analytics providers (Account Data, Data about your accounts with other services, Usage Data, Cookie Data);
• Identification of unique users across devices (Account Data, System Data, Cookie Data);
• Advertising on all devices (Cookie data);
• Improving the Services section and developing new products, services and features (all data categories);
• Analyzing trends and traffic, tracking purchases and tracking usage data (Account Data, Learning Data, Student Payment Data, Messaging and Support, System Data, Usage Data, Approximate Geographic Location, Cookie Data);
• Advertising the Services on third-party websites or applications (Account Data, Cookie Data);
• Compliance with legal requirements or permissions (all categories of data);
• Ensuring the security or privacy of our users, employees, third parties, the public, or the Services section in a manner we deem appropriate (all categories of data).

To whom we share your data

We share certain data about you with faculty, other students, companies that provide services to us, affiliated DouSpen partners, our business partners, analytics and data enrichment service providers, your social media providers, companies that help us run promotions and surveys, and advertising companies that help us advertise our Services. We may also transfer your data as necessary for security, compliance or corporate restructuring purposes. Finally, we may transfer data in other ways if it is presented in aggregate or anonymous form or if we obtain your consent to the transfer.

We may disclose your data to third parties under the following circumstances or as described in this Privacy Policy:

• Transmission of data to your instructors: We share the data we have about you (other than your email address) with instructors or teaching assistants of educational materials to which you have access or about which you have requested information so that they can improve their materials for you and other students. This information may include your country, browser language, operating system, device settings, the site from which you accessed DouSpen and your particular activities on DouSpen, such as registering for courses and checking courses. We will not share your email address with instructors or teaching assistants. (Account Data, System Data, Usage Data, Approximate Geographic Location)
• Transmission of data to other students and faculty: Depending on your settings, your published materials and profile data may be available for viewing by others, including other students and faculty.
• Data Transfers to Service Providers, Contractors and Agents: We share your data with third-party companies that provide services on our behalf, such as payment processing, anti-fraud and violence, data analysis, marketing and advertising services (including redirected advertising), email and hosting services, and customer service and support. These service providers may have access to your personal data and are required to use it, at our direction, solely to provide the services we have requested. (All Data Categories).
• With respect to DouSpen affiliate partners: We may transfer your data within our corporate group of companies that are bound by a joint ownership and management relationship necessary to implement and support the Services we provide. (All Data Categories).

• Data transfers to business partners: We have agreements with other websites and platforms to distribute our Services and to attract users to the DouSpen website. Depending on your location, we may share your data with such trusted partners. (Account Data, Training Data, Messaging and Support, System Data)
• With organizations that provide additional education credits. If you have selected a course for additional vocational training, We may provide this information upon request from the additional training loan organization. (Account information, Learning data)
• Transmission of data to data analysis and enrichment services: As part of our use of third-party analytics tools, such as Google Analytics, and data enrichment services, such as ZoomInfo, we transfer certain contact information or anonymized data. Anonymized data is data from which we have removed elements such as your name and email address and replaced it with a token identifier. This allows such service providers to provide analytics services or to compare your data with publicly available databases (including contact information and social information from other sources). We do this for a more efficient and personalized interaction with you. (Account Data, System Data, Usage Data, Cookie Data)
• Social Media Features: Social media features on the Services (for example, the Facebook “Like” button) allow third party social media providers to receive certain information, such as your IP address and the pages you visit while using the Services, and to set cookies to enable the features. Use of these features is governed by the third party’s privacy policy. (System data, Usage data, Cookie data)
• Data transfer for promotions and surveys: We may transfer your data needed to run, market or sponsor promotions and surveys in which you wish to participate, in accordance with applicable law (e.g. to provide lists of winners and fill out applications) or in accordance with the rules of the promotion or survey. (Account Data, Sweepstakes, Promotions and Surveys) Transmission of data for security and compliance purposes: We have the right to disclose your data (all categories of data) to third parties at our discretion if we believe in good faith that the disclosure
• is requested in connection with a judicial, governmental or legal inquiry, order or proceeding;
• is reasonably necessary pursuant to the effect of a subpoena, order or other valid request;
• Reasonably necessary to comply with our Terms of Use, Privacy Policy or any other legal agreements;
• is required to detect, suppress or respond to fraud, abuse, misuse, possible violations of law (or rules and regulations), security or technical issues;
• in our discretion is required or reasonably necessary to protect against the imminent threat of infringement, damage to the property or safety of DouSpen, our users, employees, members of the public or our Services;
• we also have the right to disclose your information to our auditors or legal advisors in accordance with our disclosure obligations and rights under this Privacy Policy;
• required or permitted by law.

Security

We use appropriate security measures depending on the type and vulnerability of the stored data. As with any system with access to the Internet, there is always the risk of unauthorized access, which is why it is so important to protect your password and contact us if you suspect that someone has gained unauthorized access to your account.

DouSpen takes appropriate security measures to protect against unauthorized access, alteration, and disclosure or destruction of your personal data that we collect and store. These measures depend on the type and vulnerability of the data. That said, unfortunately, no system can be 100% secure, and we cannot guarantee that unauthorized third parties will not have full access to the communications between you and DouSpen, the Services section or any information provided to us in connection with the data we collect through the Services section. Your password is an important part of our security and you are responsible for protecting it. You must not share your password with any third party, and if you believe that your password or account has been compromised, you must immediately change your password and report your suspicions to our support team.

Your Rights

You have certain rights regarding the use of your data, including the ability to opt out of receiving promotional emails, cookies and the collection of your data by certain third parties. You may renew or terminate your account through our Services platform, and you may contact us to exercise your personal rights regarding your personal data. Parents who believe that we have inadvertently collected personally identifiable information about their minor child should contact us to have that information deleted.

6.1 Your choice about how we use your information

You may choose not to provide us with some data, but then you will not be able to use certain features of the Services.

• To opt out of receiving promotional emails from us, you can unsubscribe to promotions by using the instructions in the email you receive or by changing your email settings in your account (in English). Please note, regardless of your email settings, we will send you transactional and/or relationship messages in the Services, including, administrative notices, order confirmations, important changes to the Services, and notices regarding our policies.
• If you are located in the European Economic Area, you may opt-out of certain Data Collection Tools by clicking on the “Cookie Options” link at the bottom of any page.
• The device or browser you use may have cookie management features that store other types of local data.

Our Children’s Policy

We respect children’s right to privacy and encourage parents and guardians to take an active role in their children’s online activities and interests. Those who are under 18 but of sufficient age to use the Internet services in their country of residence (e.g. 13 in the US and 16 in Ireland) cannot create an account, but can ask their parent or guardian to create an account to gain access to the relevant materials. Individuals who are not of sufficient age to use the Internet Services are not eligible to use the Services. If we discover that the personal information of a child who is under age has been collected, we will take appropriate action to delete it.

Parents who believe that DouSpen may have obtained the personal data of their underage child may send a request for deletion of such data to [email protected].