Finally, please note that some of the above mentioned Personal Data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your Personal Data and further use it. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).

2. HOW WE PROTECT AND RETAIN YOUR INFORMATION
   • Security. We have implemented appropriate technical, organizational and security measures designed to protect your Personal Data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
   • Retention of your Personal Data. Your Personal Data will be stored until we delete the record and we proactively delete it or you send a valid deletion request, please note that in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. Regarding retention of cookies, you can read more in our cookie policy https://lexiteach.com/cookie-policy/.

3. HOW WE SHARE YOUR PERSONAL DATA

In addition to the recipients described above, we may share your Personal Data as follows:

• With our business partners with whom we jointly offer products or services. We may also share Personal Data with our affiliated companies.
• To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order. We may use or disclose the information we collect in order to ensure that our users are complying with all applicable aspects of our policies;
• We may disclose information with our lawyers, accountants, auditors and other professional advisors where necessary to obtain legal or other advice or otherwise protect and manage our business interests;
• We may use or disclose the Personal Data to investigate, prevent, or take action regarding illegal activities, suspected fraud, cybersecurity threats, situations involving potential threats to the physical safety of any person, violations of this policy, or as otherwise required or allowed by law and regulations;
• If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your Personal Data to such third party (whether actual or potential) in connection with the foregoing events;
• In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Data in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company; and/or
• Where you have provided your consent to us sharing or transferring your Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).
• If you want to receive the list of the current recipients of your Personal Data, please make your request by contacting us to [email protected].

4. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA

Internal transfers: Transfers within the Gloww group will be covered by an internal processing agreement entered into by members of the Gloww group (an intra-group data processing agreement) which contractually obliges each member to ensure that Personal Data receives an adequate and consistent level of protection wherever it is transferred to.

External transfers: Where we transfer your Personal Data outside of EU/EEA (for example to third parties who provide us with services), we will generally obtain contractual commitments from them to protect your Personal Data

5. YOUR PRIVACY RIGHTS. HOW TO DELETE YOUR ACCOUNT
   • Rights:
     • The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):

1. You have a right to access Personal Data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
2. You have the right to request that we rectify any Personal Data we hold that is inaccurate or misleading;
3. You have the right to request the erasure/deletion of your Personal Data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your Personal Data, for example for the establishment, exercise or defense of legal claims;
4. You have the right to object, to or to request restriction, of the processing;
5. You have the right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
6. You have the right to object to profiling;
7. You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
8. You also have a right to request certain details of the basis on which your Personal Data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;
9. You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

• You can exercise your rights by contacting us at [email protected]. You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

• Deleting your account: Should you ever decide to delete your account, you may do so by emailing [email protected]. If you terminate your account, any association between your account and Personal Data we store will no longer be accessible through your account. However, given the nature of sharing on certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public.
• Marketing emails – opt-out: You may choose not to receive marketing email of this type by sending a single email with the subject “BLOCK” to [email protected]. Please note that the email must come from the email account you wish to block OR if you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails, and we will process your request within a reasonable time after receipt.

6. INTERACTION WITH THIRD PARTY PRODUCTS. We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

7. ANALYTIC TOOLS/COOKIES

Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with Personal Information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.

Facebook Pixels and SDKs. We use Facebook pixels or SDKs, which are tools that provide help to website owners and publishers, developers, advertisers, business partners (and their customers) and others integrate, use and exchange information with Facebook, as such the collection and use of information for ad targeting. Please note that third parties, including Facebook, use cookies, web beacons, and other storage technologies to collect or receive information from your websites and elsewhere on the internet and use that information to provide measurement services and target ads. Facebook’s ability to use and share information is governed by the Facebook Tools Terms, available at: https://www.facebook.com/legal/technology_terms/. You can prevent your data from being used by Facebook Pixels and SDKs by exercising your choice through these mechanisms: http://www.aboutads.info/ choices or http://www.youronlinechoices.eu/.

UTMGrabber. We use a tool called UTM Grabber (also known as HandL UTM Grabber), a cookie-based tracker that helps us understand how users arrive at and interact with our website based on marketing campaign data. This tool is exposed to marketing parameters like UTM variables. It also collects technical data such as your IP address, browser type, operating system, and information related to the landing page and original referral URL, as well as data regarding form submissions and other website events. The use of this data allows us to analyze the effectiveness of our marketing campaigns, track user journeys, and understand user habits and characteristics on our website. UTM Grabber’s terms of use (available at https://utmgrabber.com/terms/) and privacy policy (available at https://utmgrabber.com/privacy/) also apply to its use.

TikTok Pixel and SDKs. We use TikTok’s Pixel or SDKs, which are tools that help website owners, app developers, advertisers, and business partners integrate with TikTok’s advertising ecosystem. These tools facilitate the collection and use of information to understand user interactions, measure ad performance, and enable ad targeting. Please note that third parties, including TikTok, may use cookies, web beacons, device identifiers, and other storage technologies to collect or receive information from your websites, apps, and elsewhere on the internet. This information is used to provide measurement services, personalize content, and target ads on and off TikTok. TikTok’s ability to use and share this information is governed by its Commercial Terms of Service (available at: https://ads.tiktok.com/i18n/official/policy/commercial-terms-of-service) and its main Privacy Policy (available at: https://www.tiktok.com/legal/page/us/privacy-policy/en – note: link may vary by region).

Google Signals. The Website uses a tool called “Google Signals” to collect information about use of the Website. When we activate Google Signals, some existing Google Analytics features are updated to also include aggregated data from Google users who have turned on “Ads Personalization” (Ads Personalization available at https://support.google.com/ads/answer/2662856/). Audiences that we create in Google Analytics and publish to Google Ads and other Google Marketing Platform advertising products can serve ads in cross device-eligible remarketing campaigns to Google users who have turned on Ads Personalization. Google Analytics collects additional information about users who have turned on Ads Personalization, base across device types and on aggregated data from users who have turned on Ads Personalization. The data is user based rather than session based. The Cross Device reports include only aggregated data. No data for individual users is ever exposed. You can modify your interests, choose whether your Personal Data is used to make ads more relevant to you, and turn on or off certain advertising services in the Ads Personalization link above.

We use log files. We use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information. We reserve the right to remove or add new analytic tools.

8. SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW

California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected]. Please note that we are only required to respond to one request per customer each year. 

CONTACT US. If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at [email protected].