CIRRAN LLC PRIVACY POLICY
This Privacy Policy applies to any visitor or user (hereinafter referred to as “You”) of the website located at www.cirran.com and any websites (singularly and collectively, “the Site”) that Cirran LLC or
its subsidiaries (singularly and collectively, “Cirran”) own and control. Cirran is sensitive to the issue of confidentiality in online dealings and is committed to protecting individual privacy. This Privacy Policy is
intended to inform users about the general approach Cirran uses in collecting, using and disseminating user information via the Site. Additionally, as the Site includes information on ClassMaster, a line of products designed to
engage middle and high school students in grades and organization, the Site may be of interest to children under the age of 13 years old. We are committed to
complying fully with the Children’s Online Privacy Protection Act (“COPPA”). Our information collection policy is described below. We urge children who are under the age of 13 to check with their parent or guardian before entering
any personally identifiable information on or through the Site.
What Personally Identifiable Information May Be Collected?
- At Cirran, it is our policy to create website content that requires minimal collection of personally identifiable information from our visitors. However, to respond to your requests or to enable you to register or to use certain features of this Site, we
may request personally identifiable information from you including, but not limited to, your name, home address, email address and/or telephone number. We do not collect any more personally identifiable information than is reasonably necessary to enable your
participation in the activities we offer. For example, we may need your name and email address to add you to an email update list, or we may require a home address and telephone number to enter you into a contest or sweepstakes. If we know that a user
is under the age of 13, we will obtain a parent’s permission before we collect or share your personally identifiable information with any third party except as
otherwise set forth in this Privacy Policy. Please note that parents may consent to the collection and use of personally identifiable information without consenting to the disclosure of such information to third parties.
- When we do collect personally identifiable information, we will only keep it until that particular activity (or set of activities) is complete. Your personally identifiable information will not be given out to third parties.
- Our Site may provide links to other websites that may have their own information collection practices. To the extent that you provide personally identifiable information to
websites that link to or from our Site, different rules may apply to the use and disclosure of your personally identifiable information.
To the extent that the Site includes third-party advertisements, the privacy policy of the advertiser providing the advertisement will govern
the use of your personally identifiable information collected during your access to the advertisement. Cirran
does not control linking practices of advertisers or sponsors and does not monitor or claim
responsibility for any content or privacy practices of such websites. Once you have clicked on
an advertisement and have left our Site, you must read the privacy policy of the advertiser or
sponsor to see how your personally identifiable information will be handled.
- On occasion, Cirran may use an advertising server developed by a third party to display
ads on our Site. Some of these ads may contain cookies that are set by third parties (advertisers,
sponsors). We do not have access to these cookies or any information that they contain. This
Privacy Policy does not cover any use of information that a third-party ad server may have
collected from you.
- Cirran may use the Site as an entry into other networked web pages and websites operated
by Cirran and its subsidiaries and affiliates (together, the "Transaction Sites"). Please note that individual
Transaction Sites may adopt privacy terms particular to the purpose of such Transaction Site or
the transaction(s) taking place on such Transaction Site. As Transaction Sites are generally
affiliated with commercial transactions that you or your business may have with Cirran,
particularly those which are password-protected or are subject to subscriptions, you understand
that the privacy terms for such sites may differ through terms in separate agreements which may
supplement or supersede these terms.
Other Types of Information That May Be Collected
- IP Addresses - An Internet protocol address, or IP address, is automatically assigned to your computer when you
access the Internet, and is used by web servers to identify your computer. When you access our
Site, we may log your IP address, however, your identity will remain anonymous to us. We log
the IP addresses for system administration and for auditing the use of our Site. We may also use
IP addresses to collect statistical information for marketing and other purposes.
- Cookies or Tracers -
From time to time, we may place information on your computer to allow us to identify you. This
information is known as a “cookie”. We will only use cookies to view information on User’s
computer’s hard drive that was placed there by a cookie from our Site, such as your preferences
or which pages you have visited on the Site. However, a cookie will not allow our Site to learn
any personally identifiable information that you have not otherwise disclosed (except as
described below). By understanding how and when our visitors use the Site, we can continually
improve our Site, as well as our products and services. If you wish to disable cookies, your
browser can be reset to refuse all cookies or indicate when a cookie is being sent.
In some instances, we use tracking scripts or "tracers" that recognize a unique identifier from a
cookie placed on your hard drive by another website. These are used by Cirran solely to
gauge the success of our own advertising. For instance, we may use a tracer to determine
whether you visit our employment pages after visiting a resume or career site where Cirran
placed a banner ad. We do not use tracers to gather information on your use of the Internet
unrelated to Cirran. Please note that Cirran does not use tracers to determine your
personally identifiable information, and you remain anonymous.
- Web Beacons - Web beacons are small files that we may place on our Site, which count the number of
unique users that have visited a specific page on the Site and the number of times a given page
has been displayed. This information is collected only in the aggregate and is generally not linked to
any personally identifiable information (except as described below).
- What happens if I register - Registration may be allowed or required on the Site. Please refer to the agreements and policies applicable to the Site for which you
provide registration information in order to assure that you understand the applicable privacy practices. Cirran may collect
registration data in order to monitor compliance with this Privacy Policy and to set up access permissions
to certain other pages on the Site.
Use of Information
Use and Sharing of Information
Cirran and its affiliates may use your personally identifiable information only as set forth herein. Anonymous data collected using cookies and
web beacons may be analyzed in the aggregate to determine collective user characteristics, to understand user traffic patterns, sales information
and user behavior on the Site. Such information also may be shared in the aggregate with third parties for advertising purposes, to enhance our
Site, to enhance our products and services, and to analyze how and where best to use our resources.
Monitoring and Compliance
Although Cirran is under no obligation to monitor the Site, we may monitor, store, review and disclose to third parties any
information, including your personally identifiable information, obtained on or through the Site as may be needed or requested to
satisfy any applicable governmental law, regulation, investigation or proceeding. Additionally, we may use IP addresses to identify
a particular user if we believe it is needed to enforce compliance with these terms or to protect our LLC, employees, Site, or customers.
Security of Personally Identifiable Information
While Cirran tries to prevent third party, non-affiliate access to personally identifiable information, you should keep in mind that
data transmission over the Internet is not 100% secure and any information disclosed online can potentially be collected and used other than
by the intended recipient. In view of the foregoing, Cirran cannot warrant that your personally identifiable information will
not be disclosed to or accessed by parties other than those authorized under this Privacy Policy.
Updates to Your Information
At your request, Cirran will make reasonable efforts to update, change or delete any personally identifiable information you have provided via the
Site. In order to enforce the terms of this Privacy Policy, resolve disputes, or provide information to satisfy applicable governmental laws
, regulations, investigations or proceedings, we may need to retain your personally identifiable information in our files. Additionally, your personally
identifiable information may be retained in residual back-up files that are a function of our network’s back-up systems.
COPPA Specifically
Cirran encourages parents and guardians to spend time online with their children. We urge parents to instruct their children never to
give out their real names, addresses, or phone numbers without the permission of a parent or guardian, when using the Internet. We
recognize a special obligation to protect personal information obtained from children, as may be collected on the Site.
In compliance with COPPA, we have adopted the following policies to keep children safe (there are a few exceptions to these policies
as noted below under the heading "Exceptions to Verifiable Parental Consent"):
- We will not knowingly collect, use, or distribute personally identifiable information from children under the age of 13 without prior verifiable
consent from a parent or guardian.
- Personally identifiable information we collect from children under the age of 13 will be used solely by Cirran or its agents for internal purposes
only and will not be sold or otherwise distributed to third parties.
- We will not knowingly ask a child under the age of 13 to divulge more information than is needed to participate in any activity, game, or service.
- We will not knowingly keep any personally identifiable information that is inadvertently included in a child's email submission, help
inquiry, or other one-time request, if we know that the child is under the age of 13. Information will be automatically purged or purged immediately after
the issue has been resolved.
- We will not knowingly post any personally identifiable information that is inadvertently included in a child's submission to a general audience
contribution area if we know that the child is under the age of 13. These submissions will be deleted and handled anonymously thereafter.
- We will not knowingly provide any direct link to websites that are unsuitable for children or teens.
- We will advise children under the age of 13 that they must obtain permission from their parent or guardian before sharing any personal information.
- Upon request, we will provide a parent or guardian with a description of the information that may have been provided about their child during a
registration process for a program, service or contest on the Site. We only ask for a child's or teen's personally identifiable
information if it is necessary to participate in the foregoing.
Notification and Verifiable Parental Consent
Before any personally identifiable information is collected, we will do our best to notify the parent or guardian that their child is participating. Notification
will include the exact nature and intended use of the information we are collecting, as well as the opportunity for the parent or guardian to prevent the use
of the information and the child's participation in the activity. For every child (anyone under 13 years of age) we require the parent or guardian to provide
verifiable parental consent such as an email, mail-in letter, fax, or phone call to Cirran.
Exceptions to Verifiable Parental Consent
There are few instances where we will not get verifiable parental consent, such as:
- Requesting the contact information of a parent or guardian for the sole purpose of obtaining verifiable parental consent or providing notification to the parent or guardian;
- Collecting a child's contact information solely to directly respond to the child's request on a one-time basis. We will not use that information to re-contact the child for any other purpose (we will purge from our system the child's personal information after responding); and
- Collecting a child's contact information and the contact information of his/her parent or guardian solely to directly respond more than once to a specific request from the child (for example, to satisfy the request for a newsletter subscription). In this instance, the parent or
guardian will be notified that the child made such a request and be informed of the information provided by the child. The parent or guardian will have an opportunity at any time to revoke the child's request (i.e., unsubscribe). We will not use the child's personal
information to re-contact the child for any other purpose.
External Links
- Occasionally, you will find links from our Site to independently owned, controlled, and/or managed websites whose content we believe will be of possible interest and value to our visitors.
- In many cases, these links represent cooperative projects or mutual links established with the organizations connected with these sites. We don't control the content of the sites accessed
by you via these links. These other sites may send you their own cookies, collect data, or solicit personal information. While we identify sponsor and advertiser areas of our Site, we do not control these cookies or the content of these third parties.
- Once you leave our servers (you can generally tell where you are by checking the URL in the location bar on your browser), the use of any information you provide is governed by the privacy
policy of the operator of the site you are visiting. That policy may differ from ours. If you can't find the privacy policy of any of these sites via a link from that site's home page, you should contact that website operator directly for more information.
- We specifically recommend that children check with their parents or teachers before connecting to any new websites.
Contact Information
If you have any questions or concerns regarding Cirran’s privacy policy, please contact us at:
Intellectual Property and Licensing
Cirran LLC
support@cirran.com