Privacy Policy
Last Updated: December 22, 2023
Thank you for becoming a part of flickoly. We, at flickoly (“flickoly,” “we,” “us”), highly value your privacy and want to ensure that you comprehend how we gather, utilize, and share information about you. This Privacy Policy details our practices related to data collection and outlines your rights concerning your personal information.
This Privacy Policy is applicable to your interactions with flickoly websites, mobile applications, APIs, and related services (collectively referred to as the “Services”). It extends to potential customers considering our business and enterprise products as well. The terms of this Privacy Policy become effective when you visit or use our Services. Please refrain from using the Services if you disagree with this Privacy Policy or any other agreement governing your use of the Services.
Table of Contents
1. What Information We Collect
2. How We Obtain Information About You
3. Purpose of Collecting Your Information
4. Entities With Whom We Share Your Information
5. Security Measures
6. Your Privacy Rights
7. Specific Regulations by Jurisdiction
8. Updates and Contact Information
1. What Information We Collect
We obtain various types of data directly from you, such as information you input, details about your consumption of content, and data from third-party platforms linked to flickoly. Additionally, we automatically collect certain data, including information about your device and your interaction with different parts of our Services. The data mentioned in this section is subject to several processing activities, including but not limited to collection, recording, structuring, storage, alteration, retrieval, encryption, pseudonymization, deletion, combination, and transmission.
1.1 Data You Provide to Us
Depending on your usage of the Services, we collect diverse data from or about you. The following examples illustrate the types of data we may collect:
– When you create an account and utilize the Services, either directly or through a third-party platform, we collect any information you furnish, including:
1.2 Data We Collect through Automated Means
Data is collected through server log files and tracking technologies, stored, and associated with user accounts.
1.3 Data From Third Parties
If you are a prospective flickoly Business enterprise or corporate client, we may obtain certain business contact information from third-party commercial sources in addition to the information you provide.
2. How We Get Data About You
We employ tools like cookies, web beacons, and similar tracking technologies to collect the data outlined above. Some of these tools offer you the ability to opt out of data collection.
2.1 Cookies and Data Collection Tools
We utilize cookies, small text files stored by your browser, to collect, store, and share data about your online activities, including on flickoly. Cookies enable us to remember preferences such as your language choice, enhancing the usability of the site. For more information on cookies, visit Cookiepedia. Additionally, we may use clear pixels or other applications in emails to monitor deliverability and open rates.
Flickoly, along with service providers like Google Analytics and third-party advertisers, employs server log files and automated data collection tools, including cookies, tags, scripts, customized links, device/browser fingerprints, and web beacons (collectively referred to as “Data Collection Tools”). These tools automatically gather System Data and Usage Data (as detailed in Section 1) when you use the Services. In certain cases, data collected through these tools may be correlated with other data collected per this Privacy Policy.
2.2 Why We Use Data Collection Tools
Flickoly uses various types of Data Collection Tools for specific purposes:
– Strictly Necessary: Essential for site access, basic functionality, security, and protection against fraudulent activities. Disabling these tools may result in the site’s partial unavailability.
– Functional: Remember browser data and preferences, provide additional site functionality, and customize content for a more relevant user experience.
– Performance: Aid in measuring and improving the Services by providing usage and performance data, visit counts, and traffic sources.
– Advertising: Deliver relevant ads based on user data, preferences, and tracking information. Service providers may receive a hashed, anonymized version of email addresses for tailored advertising.
– Social Media: Enable social media functionality for content sharing. These tools may track user or device activity across sites for targeted advertising.
You can configure your web browser settings to receive alerts about cookie placement attempts, limit allowed cookie types, or reject cookies entirely. However, doing so may limit or disable some features of the Services, resulting in a different or less functional user experience. Refer to Section 6.1 (Your Choices About the Use of Your Data) below for more information on managing Data Collection Tools.
3. What We Use Your Data For
We utilize your data for various purposes to ensure the provision and improvement of our Services, effective communication, problem resolution, fraud prevention, and compliance with legal obligations. The data retention period corresponds to the duration necessary to fulfill the intended purposes. The following outlines the uses of collected data:
- Provide and administer the Services, including to facilitate participation in educational content, issue completion certificates, display customized content, and facilitate communication with other users (Account Data; Shared Content; Learning Data; System Data; Usage Data; Approximate Geographic Data);
- Process payments to instructors and other third parties (Student Payment Data; Instructor Payment Data);
- Process your requests and orders for educational content, products, specific services, information, or features (Account Data; Learning Data; Student Payment Data; System Data; Communications and Support);
- Communicate with you about your account by (Account Data; Shared Content; Learning Data; Sweepstakes, Promotions, and Surveys; System Data; Communications and Support):
– Responding to your questions and concerns;
– Sending you administrative messages and information, including messages from instructors, students, and teaching assistants; notifications about changes to our Service; and updates to our agreements;
– Sending you information, such as by email or text messages, about your progress in courses and related content, rewards programs, new services, new features, promotions, newsletters, and other available instructor-created content (which you can opt out of at any time);
– Sending push notifications to your wireless device to provide updates and other relevant messages (which you can manage from the “options” or “settings” page of the mobile app);
- Manage your account and account preferences and personalize your experience (Account Data; Learning Data; Student Payment Data; Instructor Payment Data; System Data, Usage Data, Cookie Data);
- Facilitate the Services’ technical functioning, including troubleshooting and resolving issues, securing the Services, and preventing fraud and abuse (Account Data; Student Payment Data; Instructor Payment Data; Communications and Support; System Data; Approximate Geographic Location);
- Verify the identity of instructors (Account Data; Instructor Payment Data);
- Solicit feedback from users (Account Data; Communications and Support);
- Market products, services, surveys, and promotions (Account Data; Learning Data; Sweepstakes, Promotions, and Surveys; Usage Data; Cookie Data);
- Market Subscription Plans to prospective customers (Account Data; Learning Data; Cookie Data);
- Learn more about you by linking your data with additional data through third-party data providers and/or analyzing the data with the help of analytics service providers (Account Data; Data About Your Accounts on Other Services; Usage Data; Cookie Data);
- Identify unique users across devices (Account Data; System Data; Cookie Data);
- Tailor advertisements across devices (Cookie Data);
- Improve our Services and develop new products, services, and features (all data categories);
- Analyze trends and traffic, track purchases, and track usage data (Account Data; Learning Data; Student Payment Data; Communications and Support; System Data; Usage Data; Approximate Geographic Data; Cookie Data);
- Advertise the Services on third-party websites and applications (Account Data; Cookie Data);
- As required or permitted by law (all data categories); or
As we, in our sole discretion, otherwise determine to be necessary to ensure the safety or integrity of our users, employees, third parties, the public, or our Services (all data categories).
4. Who We Share Your Data With
We may share data with various entities, including:
– Instructors and Students: Sharing relevant data with instructors and teaching assistants for educational improvement, excluding email addresses.
– Service Providers, Contractors, and Agents: Sharing data with third-party companies providing services on our behalf.
– Flickoly Affiliates: Sharing data within our corporate family for support in providing Services.
– Business Partners: Sharing data with trusted partners to distribute Services and drive traffic to flickoly.
– Analytics and Data Enrichment Services: Sharing contact information or de-identified data with third-party analytics tools and data enrichment services.
– Social Media Providers: Allowing third-party social media providers to collect data for social media features.
– Promotions and Surveys Administration: Sharing data to administer, market, or sponsor promotions and surveys.
– Advertising: Sharing System Data with third-party advertisers for targeted ad delivery, personalized user experience, and web analytics.
– Security and Legal Compliance: Disclosing data to third parties as required for security, legal compliance, or addressing imminent harm.
– During a Change in Control: Sharing data during business transactions such as mergers, acquisitions, or asset sales.
– After Aggregation/De-identification: Disclosing or using aggregated or de-identified data for any purpose.
– With Your Permission: Sharing data outside the scope of this Privacy Policy with your consent.
5. Security
At flickoly, we prioritize the security of your data by implementing appropriate measures tailored to the type and sensitivity of the information stored. However, as is the case with any internet-enabled system, there is inherent risk of unauthorized access. It is imperative to safeguard your password, and in the event of any suspicion of unauthorized access to your account, we encourage you to promptly contact us.
Flickoly employs diligent security measures designed to thwart unauthorized access, alteration, disclosure, or destruction of the personal data that we collect and store. These measures are adapted to the specific type and sensitivity of the data in question. Regrettably, despite our best efforts, no system can provide absolute assurance, and we cannot guarantee that communications between you and flickoly, the Services, or any information provided in connection with the data we collect will be entirely free from unauthorized access by third parties.
Your password constitutes a crucial component of our security system, and its protection falls under your responsibility. Sharing your password with any third party is strongly discouraged. Should you suspect any compromise of your password or account, we urge you to change it immediately and reach out to our Support Team with any concerns. Maintaining the confidentiality of your password is vital to ensuring the security of your account.
6. Your Rights
As a user, you possess specific rights concerning the utilization of your data, granting you the authority to opt out of promotional emails, control cookie settings, and restrict the collection of your data by specific third parties. Within our Services, you retain the ability to update or terminate your account. Additionally, you can reach out to us for individual rights requests related to your personal data. Parents who believe that unintentional collection of personal data about their underage child has occurred should contact us for assistance in deleting that information.
6.1 Your Choices About the Use of Your Data
You retain the freedom to decide not to furnish certain data to us; however, this may result in the limitation of access to specific features within the Services.
· To stop receiving promotional communications from us, you can opt out by using the unsubscribe mechanism in the promotional communication you receive or by changing the email preferences in your account. Note that regardless of your email preference settings, we will send you transactional and relationship messages regarding the Services, including administrative confirmations, order confirmations, important updates about the Services, and notices about our policies.
· If you’re located in the European Economic Area, you may opt out of certain Data Collection Tools by clicking the “Cookie settings“ link at the bottom of any page or send us mail for same.
· The browser or device you use may allow you to control cookies and other types of local data storage. To learn more about managing cookies, visit https://cookiepedia.co.uk/how-to-manage-cookies. Your wireless device may also allow you to control whether location or other data is collected and shared.
· To get information and control cookies used for tailored advertising from participating companies, see the consumer opt-out pages for the Network Advertising Initiative and Digital Advertising Alliance, or if you’re located in the European Economic Area, visit the Your Online Choices site. If you’re located in Japan, visit the Digital Advertising Consortium. To opt out of Google’s display advertising or customize Google Display Network ads, visit the Google Ads Settings page. To opt out of Taboola’s targeted ads, see the Opt-out Link in their Cookie Policy.
· To opt out of allowing Google Analytics, Mixpanel, ZoomInfo, or Clearbit to use your data for analytics or enrichment, see the Google Analytics Opt-out Browser Add-on, Mixpanel Opt-Out Cookie, ZoomInfo’s policy, and Clearbit data claiming mechanism.
· Apple iOS, Android OS, and Microsoft Windows each provide their own instructions on how to control in-app tailored advertising. For other devices and operating systems, you should review your privacy settings on that platform.
If you have any questions about your data, our use of it, or your rights, contact us at privacy@ flickoly.com.
6.2 Accessing, Updating, and Deleting Your Personal Data
You can access and update your personal data that flickoly collects and maintains as follows:
· To update data you provide directly, log into your account and update your account at any time.
· To terminate your account:
- If you are a student, visit your profile settings page and follow the steps detailed here
- If you are an instructor, follow the steps detailed here.
If you have any issues terminating your account, please contact our Support Team.
Please note: even after your account is terminated, some or all of your data may still be visible to others, including without limitation any data that has been (a) copied, stored, or disseminated by other users (including comments on content); (b) shared or disseminated by you or others (including in your shared content); or (c) posted to a third-party platform. Even after your account is terminated, we retain your data for as long as we have a legitimate purpose to do so (and in accordance with applicable law), including to assist with legal obligations, resolve disputes, and enforce our agreements. We may retain and disclose such data pursuant to this Privacy Policy after your account has been terminated.
To request to access, correct, or delete your personal data, please use our online form [here](link). You can also submit these requests by emailing us at privacy@flickoly.com or writing to us at flickoly, Attn: Privacy/Legal Team, office # SK236/II, Ground Floor, Sec 116, Noida, Uttar Pradesh 201301.
Please allow up to 25-30 days for a response. For your protection, we may require that the request be sent through the email address associated with your account, and we may need to verify your identity before implementing your request. Please note that we retain certain data where we have a lawful basis to do so, including for mandatory record-keeping and to complete transactions.
6.3 Our Policy Concerning Children
We recognize the privacy interests of children and encourage parents and guardians to take an active role in their children’s online activities and interests. Individuals younger than 18 years of age, but of the required age for consent to use online services where they live (for example, 18 in India, 13 in the US and 16 in Ireland), may not set up an account but may have a parent or guardian open an account and help them access appropriate content. Individuals younger than the required age for consent to use online services may not use the Services. If we learn that we’ve collected personal data from a child under those ages, we will take reasonable steps to delete it.
Parents who believe that flickoly may have collected personal data from a child under those ages can submit a request that it be removed to privacy@flickoly.com.
7. Jurisdiction-Specific Rules
If you live in California, you have certain rights related to accessing and deleting your data, as well as learning who we share your data with. If you live in Australia, you have the right to make a formal complaint with the appropriate government agency. Users outside of the United States should note that we transfer data to the US and other areas outside of the European Economic Area.
Users who are California residents have certain rights under the California Consumer Privacy Act, (“CCPA”). If you are an eligible California user, included in these rights are:
– “Right to Know” — You have the right to request to know more about the categories and specific pieces of personal information that we have collected about you and access a copy of your personal information.
– “Right to Correction” — You have the right to have inaccurate personal information about you corrected.
– “Right to Deletion” — You have the right to request deletion of personal information that we have collected about you.
– “Right to Non-Discrimination” — If you choose to exercise any of your rights under CCPA, flickoly will treat you like all other users. In other words, there is no penalty for exercising your rights under CCPA.
– “Right to Opt-Out” – You have the right to opt out of the sale or sharing of your personal information.
7.1 Users in the European Economic Area (“EEA”) and United Kingdom (“UK”)
If you are located in the EEA or UK, you have the right to request access to your data in a portable format and to request the rectification, erasure, restriction of processing, or objection to processing of your personal data. You may use the information in Section 6.2 to submit your request. Additionally, if you are located in the EEA, UK, or Switzerland, you also have the right to lodge a complaint with your supervisory authority.
Personal data is also processed outside of the UK, Switzerland, and the EEA by our flickoly group companies or our service providers, including to process transactions, facilitate payments, and provide support services as described in Section 4. We use the Controller-to-Processor Standard Contractual Clauses adopted by the European Commission to facilitate transfers of personal data from the EEA to third countries and have entered into data processing agreements with our service providers and flickoly group companies to restrict and regulate their processing of your data. By submitting your data or using our Services, you consent to this transfer, storage, and processing by flickoly and its processors.
7.2 Data Privacy Framework
We are committed to subject to the DPF Principles all personal data received from the European Union, UK and Gibraltar, and Switzerland. The types of personal data collected are described in Section 1 of this Privacy Policy. The purposes for which we collect and use personal data are described in Section 3 of this Privacy Policy. The type of third parties to whom we disclose personal data are described in Section 4 of this Privacy Policy. We remain responsible for any of your personal data that is shared under the Onward Transfer Principle with third parties for external processing on our behalf. Additionally, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. flickoly shall remain liable under the DPF Principles if its agent processes personal information in a manner inconsistent with the DPF Principles unless flickoly proves that it is not responsible for the event giving rise to the damage.
Individuals have the right to access their personal data, and instructions on doing so are provided in Section 6.2 of this Privacy Policy. Individuals may also limit the use and disclosure of their personal data as described in Section 6.1.
In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, flickoly commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU, UK, and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, should first contact flickoly at privacy@flickoly.com.
8. Updates & Contact Info
When we make a material change to this policy, we’ll notify users via email, in-product notice, or another mechanism required by law. Changes become effective the day they’re posted. Please contact us via email or postal mail with any questions, concerns, or disputes.
8.1 Modifications to This Privacy Policy
From time to time, we may update this Privacy Policy. If we make any material change to it, we will notify you via email, through a notification posted on the Services, or as required by applicable law. We will also include a summary of the key changes. Unless stated otherwise, modifications will become effective on the day they are posted.
As permitted by applicable law, if you continue to use the Services after the effective date of any change, then your access and/or use will be deemed an acceptance of (and agreement to follow and be bound by) the revised Privacy Policy. The revised Privacy Policy supersedes all previous Privacy Policies.
8.2 Interpretation
Any version of this Privacy Policy in a language other than English is provided for convenience. If there is any conflict with a non-English version, you agree that the English language version will control.
8.3 Questions
If you have any questions, concerns, or disputes regarding our Privacy Policy, please feel free to contact our privacy team (including our Data Protection Officer) at privacy@flickoly.com (mailto:privacy@flickoly.com). You can also send postal mail to us at: flickoly e-Learning Solutions, Office # SK 236/II, Ground Floor, Sector 116, Noida, Uttar Pradesh 201301.