Additional privacy information for California residents
If you are a California resident, the California Consumer Privacy Act (“CCPA”) requires us to provide you with the following additional information about: (1) the purpose for which we use each category of “personal information” (as defined in the CCPA) we collect; and (2) the categories of third parties to which we (a) disclose such personal information for a business purpose, (b) “share” personal information for “cross-context behavioral advertising,” and/or (c) “sell” such personal information. Under the CCPA, “sharing” is defined as the targeting of advertising to a consumer based on that consumer’s personal information obtained from the consumer’s activity across websites, and “selling” is defined as the disclosure of personal information to third parties in exchange for monetary or other valuable consideration. Our use of third-party online advertising services, which are described in detail above, may result in the disclosure of online identifiers (e.g., cookie data, IP addresses, device identifiers, and usage information) in a way that may be considered a “sale” or "sharing" under the CCPA.
The following chart provides information about our practices in the 12 months leading up to the effective date of this Privacy Policy:
| Category of Personal Information | Purposes of Use | Categories of Third Parties to Which We Discloses this Personal Information | Categories of Third Parties to Which We “Share” and “Sell” this Personal Information for Advertising/Analytics Purposes |
| Contact information (such as your full name, email address, and physical address) | Provide the Services; Process orders; Communicate with you; Marketing and advertising; Analyze use of and improve the Services; With your consent; Comply with law or defend our legal rights; Security/fraud prevention; Create aggregate/de-identified information | Affiliated entities; Service providers; Your Institution; Online advertising and analytics partners; Entities for legal purposes | Online advertising and analytics partners |
| Transaction, payment, and order information | Provide the Services; Process orders; Communicate with you; Analyze use of and improve the Services; Personalize your experience and customize the Services; With your consent; Comply with law or defend our legal rights; Security/fraud prevention; Create aggregate/de-identified information | Affiliated entities; Service providers; Entities for legal purposes | We do not share/sell |
| Interaction information (such as ratings, reviews, recommendation, and other public feedback) | Provide the Services; Process orders; Communicate with you; Analyze use of and improve the Services; Personalize your experience and customize the Services; With your consent; Comply with law or defend our legal rights; Security/fraud prevention; Create aggregate/de-identified information | Affiliated entities; Service providers; Your Institution; Online advertising and analytics partners; Entities for legal purposes | We do not share/sell |
| Customer service interaction information | Provide the Services; Communicate with you; Analyze use of and improve the Services; With your consent; Comply with law or defend our legal rights; Security/fraud prevention; Create aggregate/de-identified information | Affiliated entities; Service providers; Entities for legal purposes | We do not share/sell |
| Surveys, sweepstakes, conference, and event information | Provide the Services; Communicate with you; Marketing and advertising; Analyze use of and improve the Services; With your consent; Comply with law or defend our legal rights; Security/fraud prevention; Create aggregate/de-identified information | Affiliated entities; Service providers; Entities for legal purposes | We do not share/sell |
| Internet network and device information (such as mobile device information, IP address, general location, and information about your interaction with the Services) | Provide the Services; Marketing and advertising; Analyze use of and improve the Services; Personalize your experience and customize the Services; With your consent; Comply with law or defend our legal rights; Security/fraud prevention; Create aggregate/de-identified information | Affiliated entities; Service providers; Online advertising and analytics partners; Entities for legal purposes; | Online advertising and analytics partners |
| Login information (such as your username and password) | Provide the Services; Process orders; Personalize your experience and customize the Services; Comply with law or defend our legal rights; Security/fraud prevention; Comply with law or defend our legal rights; Create aggregate/de-identified information | Affiliated entities; Service providers; Entities for legal purposes | We do not share/sell |
| Audio or visual information (such as information collected from an event or program or audio recordings if you call our customer service phone number) | Provide the Services; Comply with law or defend our legal rights; Security/fraud prevention; Comply with law or defend our legal rights | Affiliated entities; Service providers; Entities for legal purposes | We do not share/sell |
| Professional or employment information (such as the name and address of a relevant Institution and your title) | Provide the Services; Communicate with you; Marketing and advertising; Analyze use of and improve the Services; With your consent; Comply with law or defend our legal rights; Security/fraud prevention; Create aggregate/de-identified information | Affiliated entities; Service providers; Entities for legal purposes; | Online advertising and analytics partners |
For more information about each category of personal information, purpose of use, and third parties to which we disclose personal information, please see the “What information do we collect about you?,” “Why do we collect your information?,” and “Who do we disclose your personal information to?” sections of our Privacy Policy.
Your Choices Regarding “Sharing” and “Selling”
As explained in the “Online analytics and advertising” section above, we provide information to third-party advertising providers for targeted advertising purposes and use advertising analytics partners to assist us in analyzing use of our Services and our user/customer base. Under applicable law, the disclosure of your personal information to these third parties to assist us in providing these services may be considered a “sale” of personal information or the “sharing/processing of your information for targeted advertising.”
If you would like to opt out of our online disclosure such as through cookie and pixel technology of your personal information for purposes that could be considered “sales” for those third parties' own commercial purposes, or “sharing” for purposes of targeted advertising, please review the information and follow the instructions in the “Online Analytics and Advertising” section above. You must make this choice on each site/app on each browser/device you use to access the Services. You must also renew this choice if you clear your cookies or your browser is set to do that. You can also submit a request to opt out of the use of your email address and other personal information related to that email address for targeted advertising purposes by visiting https://shop.epslearning.com/contact-us. Depending on your jurisdiction, you may be permitted to designate an authorized agent to submit such requests on your behalf. Please note that we do not knowingly sell the personal information of minors under 16 years of age.
Other CCPA Rights
If we ever offer any financial incentives in exchange for your personal information, we will provide you with appropriate information about such incentives.
Please see the “Your rights and choices” section of our Privacy Policy above for information about the additional rights you have with respect to your personal information under California law and how to exercise them.
Retention of Your Personal Information
Please see the “How long do we retain your information?” section above.
Shine the Light Disclosure
The California "Shine the Light" law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we disclose certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We currently do not disclose your personal information to third parties for their own direct marketing purposes.