If you have questions about this policy, please feel free to contact us at:
1. Information We Collect
In describing our collection, use, and sharing of information in this Policy, we refer to our collection and use of “Personal Information” (PI). PI, as used in this Policy, is Personally Identifiable Information (PII), which is information that directly identifies an individual, such as first and last name, mailing address, email address, billing information, IP addresses, demographics, passwords or other online contact information, or telephone number. We collect PI, as well as non-personally identifiable information on TWJ Sites and/or Services.
We collect PI in two ways. First, we collect information you provide to us in optional, voluntary submissions, such as in registration forms, user profiles, promotional signups, sweepstakes/contest entries, requests for customer service, software and mobile applications downloads and curriculum vitae submissions. Second, some PI may be collected automatically. This is described below in “Passive Data Collection.”
We may also obtain information, including PI, from third party sources. If we directly combine information from third parties with PI that we have collected, we will treat the combined information as PI and handle it in accordance with this Policy. In addition, please note that we may solicit third parties to collect PI on our behalf and in such cases we instruct those third parties to comply with this Policy and all applicable data protection laws.
Please be aware that we are prohibited from conditioning a child’s participation in any activity on that child disclosing more personal information than is reasonably necessary to participate in that activity. You are under no obligation to provide, and can decline to provide, any requested information at any time. However, if you decline to provide personal information that is reasonably necessary to participate in certain activities, you may not be able to participate in those activities on certain Sites and/or Services.
Passive Data Collection
We may receive passively-collected information through a variety of methods including but not limited to:
We may use a variety of methods, including “cookies” to collect information.
What is a cookie?
Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow a website to recognize a user’s device. You can find more information about cookies at: www.allaboutcookies.org.
Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving your user experience.
The cookies used on our Sites and/or Services have been categorized based on the categories found in the ICC UK Cookie guide. A list of all the cookies used on our Sites and/or Services by category is set out below.
TWJ collects cookies on our Sites and/or Services to capture information about page visits (e.g. “performance cookies.”) This information is both anonymous and protected, and TWJ uses this information only internally – to deliver the most effective content to our visitors. Information from the cookie is used to gauge page popularity, analyze traffic patterns on our Sites and/or Services and guide development of other improvements to our Sites and/or Services.
Targeting, Performance, and Functionality Cookies
TWJ currently maintains no targeting or performance cookies. Should this change in the future, changes will be reflected within this section of this policy.
Functionality and Necessary Cookies
Opting Out of Cookies
You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether or not to accept it. You may also change your cookie settings through preference options in our Sites and/or Services, where applicable. We will indicate that upon selecting your preferences, that we will use a cookie to remember your preferences.
TWJ never gives away information about our users. If you choose to provide PI about yourself, TWJ will use this information only to communicate directly with you. TWJ will never sell, rent or otherwise disclose that information to third parties unless such disclosure is necessary for the purposes set forth in this Policy, by law or a policy or notice contained or associated with a specific Site(s) and/or Service(s).
We may collect, use, and share (with TWJ partners, service providers and licensees) precise location data, including the real-time location of your mobile or fixed location device. This information is both anonymous and protected, and TWJ uses this information only internally as a way to understand and analyze traffic patterns on our Sites and/or Services and guide development of other improvements to our Sites and/or Services.
We use analytics tools and other third party technologies, such as Google Analytics, to collect non-personal information in the form of various usage and user metrics when you use our online Sites and/or Services. These tools and technologies collect and analyze certain types of information, including cookies, IP addresses, device and software identifiers, referring and exit URLs, onsite behavior and usage information, feature use metrics and statistics, usage and purchase history, MAC Address, mobile unique device ID, and other similar information.
The third party analytics companies who collect information on our Sites and/or Services and other online products and/or services may combine the information collected with other information they have independently collected from other websites and/or other online or mobile products and services relating to your activities across their network of websites as well as online and/or mobile products and services. Many of these companies collect and use information under their own privacy policies. TWJ does not have authority or control over the policies of other companies.
In addition to our use of technologies as described herein, we may permit certain third party companies to help us tailor advertising that we think may be of interest to you based on your use of TWJ Sites and/or Services and to otherwise collect and use data about your use of TWJ Sites and/or Services. For more information about this practice, please see the “Third Party Advertising Technologies” section below.
2. How We Use Information
Generally, we use PI to establish and enhance our relationship with our users through four main categories: (1) Communication; (2) Optimization; (3) Advertising; and (4) Sharing Features. Below, we provide some specific examples of how we use the PI and other information we collect.
Communication and Responding to Requests
We use your information, including PI to provide you with customer support, process transactions, respond to users’ requests, send newsletters and updates, send special offers and advertisements, seek your opinions and feedback, and connect users to TWJ Sites and/or Services, and to products and services of our partners and licensees.
We use user information, including PI, behavioral metrics, and other non-personally identifiable information to operate, provide, improve, and maintain our Sites and Services, to develop new products and services, to prevent abuse and fraud, to personalize and display advertisements and other content for you, and for other administrative and internal business purposes.
In the future, we may use user information, including PI, to personalize and display advertisements and other content for you.
We use your information, including PI and any other information you submit directly or through passive means to provide you with various ways to connect and share content (e.g., web content, user generated videos, text, drawings, and screen and lecture captures, media, tools, services and other products) with third parties. For example, we may provide you with the opportunity to email a link to certain content to another person. To use this feature, we may require you to provide certain PI including your email address and the email address of each person to whom you send the link.
We also may allow you to share links to content with users of various third party services (e.g., social networking, search and sharing services). When sharing links using one of these third party services, if you are not already logged in to the third party service, you will need to supply login credentials for it. If you are not a registered user of the third party service, you will need to sign up for it. You are supplying the registration information or login credentials for the third party service directly to that third party, and not to us. By using any of these third party services to share links to content, you permit us to access, use and disclose any information relating to your account on each such third party service (such as your user name and profile information) that is available to us through the third party service, including through its application programming interface (API) pursuant to this Policy.
3. When We Disclose Personal Information
We do not share Personal Information with third parties except in the limited circumstances described in this Policy.
We may provide PI to third parties for their use in performing internal business functions (e.g., payment processing, customer service, maintenance, security, data analysis, email transmission, beta testing, or data hosting) on our behalf. Additionally, some third party service providers may collect information, including PI, on our behalf. Whenever possible, we require such third-parties to only collect and use PI in accordance with this Policy, to maintain the confidentiality, security, and integrity of such PI, and for no purpose other than providing us with our requested services. TWJ reserves the right to take legal action against any third party who violates such agreements, collects PI from us without consent, or attempts or succeeds in using any collected PI from us in any manner inconsistent with this policy, to include the strict maintenance of confidentiality, security and integrity.
Note: the term “may” indicates the ability to take and action, but the requirement to take said action.
Change of Ownership
Information about our users, including PI, may be disclosed as part of any bankruptcy, merger, sale, transfer of company assets, acquisition, or similar transaction. In the event of such a transaction in which your PI would be transferred to a third party, we will make reasonable efforts to notify you. For example, we will post a notice of the transfer of PI on our Sites and/or Services and, if we have your email address, we may send notice of the transfer of PI to that email address.
If you use a forum, blog, channel, bulletin board, chat room, user commenting features, or other interactive sharing or social features that may be offered through any of our Sites and/or Services, you should be aware that any PI you submit, display, or publish there is considered publicly available and can be read, collected, used, and disclosed by other users of those features, by us, and other third parties without restriction, except to the extent limited access features are available, if any. To request removal of your PI from our blog, sharing service or community forum, should you post said PI and subsequently be unable to remove the information yourself, contact us at the information provided in this Policy. In some cases, we may not be able to remove your PI, in which case we will let you know if we are unable to do so and why.
4. Third Party Advertising Technologies
TWJ currently maintains no targeted advertisements. Should TWJ use targeted advertising content in the future, and you decide to opt-out of targeted cookies (as described in this policy), you will continue to receive the display of generic ads that we authorize on our site.
5. Children Under 13
We do not knowingly seek or collect PI from users under the age of 13, except to the extent that TWJ may collect limited personal information from students (but not their email addresses), but only where that student’s school, district, and/or teacher has contracted with TWJ to collect the personal information from students for the use and benefit of the learning environment. Children under 13 years old are not allowed to create an account without a parent’s or guardian’s express consent. We recommend that minors over the age of 13 ask their parents for permission before sending any information about themselves to anyone over the Internet.
We require schools, districts, and/or teachers to obtain parental or guardian consent from a students’ parent or guardian before collecting any such student PI. If you are a student, please do not send any PI about yourself to us, other than what we request from you when you sign up for any of our Sites and/or Services. In the event that we learn that we have collected PI from a student without parental consent being obtained by his or her school, district, and/or teacher, or if we learn a student has provided us PI beyond what we request when he or she signs up for any of our Sites and/or Services, we will delete that information as quickly as possible. If you believe that a student may have provided us PI beyond what is requested when signing up for any of our Sites and/or Services, or that a student’s school, district, or teacher has not obtained parental consent, please contact us at: firstname.lastname@example.org
Notwithstanding anything to the contrary contained in this Policy, if you are a student as described above, and your parent or guardian signed up for our Sites and/or Service with a password or access ID provided by your teacher, you understand that your parent or guardian may be able to view all information within or associated with your account, including, without limitation, messages between you and your teacher and grades you received on your assignment.
Users under 13 years of age who are not students as described above, your continued use of the Site and/or Service will be considered by TWJ as confirmation that your parent or guardian has expressly consented to the handling of your personal information as described in this Policy as further indicated in the opening paragraph of this Policy.
6. Your Choices
Submitting Personal Information
If you do not want to submit PI that is necessary to provide or use our Sites and/or Services or to fulfill your request, you will not be able to access and/or participate in certain TWJ Sites and/or Services. For example, you will not be able to register for an account with us or participate in certain contests or promotions, or access and/or use certain TWJ product features or online services. In addition, your refusal to submit PI may limit our ability to respond to your customer support inquiry in a timely fashion.
Editing Personal Information
You may, at any time, update, correct, or delete certain PI that you have provided to us by updating your preferences on the Account Settings page or by contacting us at the mailing or email address provided set forth in this Policy.
If you want to remove yourself from individual communications, including marketing promotions, advertisements, updates and email newsletters, simply click the unsubscribe link in the communication or access your Account Settings page when logged in. You also acknowledge and agree that there may be instances where we may elect to notify you about administrative notices regarding your account with us, such as to inform you about changes to our terms, conditions, and policies, that your account may be expiring, or to provide you with other relevant administrative information about your account. Because this information is important to your interaction with us, you may not opt out of receiving these communications.
If you submit PI, you may delete your account with us at any time. If you delete your account, your PI and any and all other account related information including, but not limited to, user profile data, purchasing history, sharing data and any other data, credits, or content specifically associated with your account are also permanently deleted. Deletion of your data may take up to 30 days from accessible systems and up to 90 days from backup systems. If you choose to have an account with us in the future, you will have to sign up for a new account as none of the information you previously provided or saved within your account will have been saved.
We take reasonable measures, including the implementation and maintenance of physical, electronic, and managerial procedures, in an effort to assure the security, integrity, and accuracy of all PI that we collect. Our efforts include procedures designed to avoid unauthorized access, alteration, misuse or disclosure of PI.
If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the TWJ Sites and/or Services covered by this Policy and providing PI to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your account information and usage.
8. Data Integrity and Data Retention
We collect and use PI in accordance with this Policy and only for the purposes stated in this Policy and/or at the time we request such PI from our users, or for such purposes to which a user may otherwise consent. We do not use or share our users’ PI in a way that is incompatible with the purposes for which such PI was requested and authorized for use by us. We retain PI for no longer than is commercially useful to carry out our business purposes, or as we believe may be legally required. When PI is deleted or updated by you, it may take up to 30 days from accessible systems, and up to 90 days from backup systems, for us to delete such PI.
9. Access to Personal Information
You may view, correct, or delete the PI TWJ stores about you. Most of your PI may be accessed and corrected by simply logging into your account and accessing your profile. If you wish to obtain a report of the PI TWJ has about you, please send us a written request at the address set forth in this Policy.
10. Third Party Login Functionality
We may permit users with accounts on certain third party services, including but not limited to, social networking, search, sharing, and other services delivered by third-parties, to bypass the standard applicable registration process. If you connect through an authorized third party service, you will be able to use your third party login information to log in to your TWJ account or access TWJ content, Sites and/or Services. We are not responsible for the sharing, posting, commenting, or other content and information gathering practices of any third party services that may be triggered by using these third party login services. Please review their terms of service and privacy policies carefully before using third party login functionality to access any TWJ Sites and/or Services.
By using any third party services to log in to your TWJ account or access TWJ Sites and/or Services, you permit us to access, store and use all information related to your third party account that may be accessible to us through the third party service, including through its application programming interface (API), pursuant to this Policy.
11. Third Party Services and Links
TWJ’s content, including forums contests, products, services, newsletters and communications that we send to our users, may contain links to content provided by third-parties. For example, our communications may contain links to third party merchants from whom you may purchase products. To purchase products from these third party merchants, you may be required to provide PI, including your credit card or other payment information.
12. California Privacy Rights
13. Changes and Updates to This Policy
We may update this Policy from time to time. If we do, we will update the “effective date” at the bottom of the Policy. If we make material changes to how we use PI, we will attempt to notify you of the change and to give you the opportunity to exercise choice as to how your PI is used. We will post the updated Policy on the affected Sites and/or Service, and if we have your email address, we will send notice of the update to that email address.
We encourage you to review this Policy periodically to stay informed about our collection, use and disclosure of PI. Your continued use of our Sites and/or Services or any other content, products or other services covered by this Policy constitutes your agreement to this Policy and any updates.
14. International Users & U.S.-EU Switzerland Safe Harbor
Some TWJ Sites and/or Services may be hosted in the United States, or any nation TWJ so chooses to obtain authorization for operations, and to where such legal provisions for services and privacy of our information is made available in accordance with TWJ policies. If you utilize such Sites and/or Services to which may be hosted within the United States from the European Union or Switzerland, or any other region with laws governing data collection and use that may differ from U.S. law, please note that you are transferring your personal data outside of those jurisdictions to the United States. The United States does not have the same data protection laws as the European Union, Switzerland and other regions. By providing PI under this Policy, you consent to the use of your PI in accordance with this Policy and the transfer of your PI to the United States. Should TWJ choose in the future to remove hosting of any of our Sites and/or Services which may be currently hosted from within the U.S., notification shall be made.
16. No Error Free Performance
Revision as of: 01MAY2015