Privacy Policy

Key Information

PlutoInnovations is the data controller of your personal information.
We collect the personal information set out in the "What Information We Collect" section of this Privacy Policy below, including account registration details, details of online courses you undertake, survey information (where you provide it), identity verification data, and information about your use of our site and services.
We use your personal information for the purposes set out in the "How We Use the Information" section of this Privacy Policy below, including providing our site and services to you, ensuring the security and performance of our site, research relating to academic courses, sharing information with our partners (such as academic institutions) and our suppliers, direct marketing and performing statistical analysis of the use of our site and services.
You have a number of rights that you can exercise in relation to our use of your personal information, as set out in the "Updating or Deleting Your Personally Identifiable Information" section of this Privacy Policy below.

You can find information about us and how we collect, use and store your personal data in each section of this privacy policy:

Purpose and who we are
The purpose of this Privacy Policy is to describe how PlutoInnovations, Inc. ("PlutoInnovations," "us," "we," or "our") collects, uses, and shares information about you through our online interfaces (e.g., websites and mobile applications) owned and controlled by us, including www.PlutoInnovations.com (collectively referred to herein as the "Site"). Please read this notice carefully to understand what we do. If you do not understand any aspects of our Privacy Policy, please feel free to contact us at privacy@PlutoInnovations.org. Your use of our Site is also governed by our Terms of Use.

PlutoInnovations, Inc. is a Delaware corporation with a principal place of business at 381 E. Evelyn Ave., Mountain View, CA 94041. If you reside or are located in the European Economic Area ("EEA") PlutoInnovations is the data controller of all Personally Identifiable Information (as defined below) collected via the Site and of certain Personally Identifiable Information collected from third parties, as set out in this Privacy Policy.

What Information this Privacy Policy Covers
This Privacy Policy covers information we collect from you through our Site. Some of our Site’s functionality can be used without revealing any Personally Identifiable Information, though, for features or services related to the Online Courses, Personally Identifiable Information is required. In order to access certain features and benefits on our Site, you may need to submit, or we may collect,

"Personally Identifiable Information" (i.e., information that can be used to identify you). Personally, Identifiable Information can include information such as your name and email address, among other things. If you reside or are located in the EEA, it can also include your IP address or device identifier. You are responsible for ensuring the accuracy of the Personally Identifiable Information you submit to PlutoInnovations. Inaccurate information may affect your ability to use the Site, the information you receive when using the Site, and our ability to contact you. For example, your email address should be kept current because that is one of the primary manners in which we communicate with you.

What You Agree to by Using Our Site
We consider that the legal bases for using your personal information as set out in this privacy policy are as follows:

our use of your personal information is necessary to perform our obligations under any contract with you (for example, to comply with the terms of use of our Site which you accept by browsing our website and/or to comply with our contract to provide services to you); or
our use of your personal information is necessary for complying with our legal obligations; or
where neither of the above applies, use of your personal information is necessary for our legitimate interests or the legitimate interests of others. Our legitimate interests are to:

run, grow and develop our business;
operate our Site and provide our services;
select appropriately skilled and qualified suppliers;
build relationships with partners and academic institutions;
carry out research and statistical analysis;
carry out marketing and business development; and
for internal administrative and auditing purposes.

If we rely on our (or another person's) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person's) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information.

We may process your personal information in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time after giving it, as described below).

If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by visiting your profile page and clicking the box to remove consent or delete your account and we will stop doing so. However, if you withdraw your consent, this may impact the ability of us to be able to provide our services to you.

What Information We Collect
We gather two types of information about users through the Site:
1. Information relating to your use of our Site. When users come to our Site, we may track, collect and aggregate information indicating, among other things, which pages of our Site were visited, the order in which they were visited, when they were visited, and which hyperlinks were "clicked." We also collect information from the URLs from which you linked to our Site. Collecting such information may involve logging the IP address, operating system, and browser software used by each user of the Site. We may be able to determine from an IP address a user’s Internet Service Provider and the geographic location of his or her point of connectivity.
We also use (or may use) cookies and web beacons when you visit our Site. For more information on our use of cookies and web beacons, please refer to our Cookie Policy.

2. Personally Identifiable Information provided directly by you or via third parties. We collect Personally Identifiable Information that you provide to us when you register for an account, update or change information for your account, purchase products or services, complete a survey, sign-up for email updates or Online Courses, participate in our public forums, send us to email messages, and/or participate in Online Courses or other services on our Site. We may use the Personally Identifiable Information that you provide to respond to your questions, provide you the specific course and/or services you select, send you updates about Online Courses offered by PlutoInnovations or other PlutoInnovations events, and send you to email messages about Site maintenance or updates.

Account Registration. If you register for an account on our Site, you may be required to provide us with Personally Identifiable Information such as your name and email address.
Updates. PlutoInnovations may offer you the ability to receive updates either via email or by posting on portions of the Site only accessible to registered users. In order to subscribe to these services, you may be required to provide us with Personally Identifiable Information such as your name and email address.
Forums. PlutoInnovations may offer public forums from time to time (the "Forums") where you can share comments and thoughts. In order to participate in the Forums, you may be required to register with us and/or provide us with Personally Identifiable Information such as your name and email address. Please keep in mind that the information you post or make available in Forums will be publicly available. You should not post any Personally Identifiable Information or other information of a personal or sensitive nature, whether relating to you or another person, on a Forum. Please also reference our Terms of Use for our Rules for Online Conduct and additional information about the proper use of our Forums.
Participation in Online Courses. PlutoInnovations offers users the opportunity to participate in an Online Course on or through the Site. If you desire to participate in a course, you will be asked to provide us with certain information necessary to conduct such a course. This information may include, among other things, your name and email address.

If you participate in an online course, we may collect from you certain student-generated content, such as assignments you submit to instructors, peer-graded assignments, and peer grading student feedback. We also collect course data, such as student responses to in-video quizzes, standalone quizzes, exams, and surveys. You should not include any Personally Identifiable Information or other information of a personal or sensitive nature, whether relating to you or another person, on assignments, exams, or surveys, except for information required to participate or submit such assignments, exams, or surveys.

Identity Verification. PlutoInnovations may offer you the ability to verify your identity for selected classes. In order to enroll in these services, you may be required to provide us or our third-party identity verification vendor with Personally Identifiable Information such as your name, address, date of birth, a headshot was taken using a webcam, and a photo identification document. Additionally, if you apply for financial aid in connection with these services, you may be required to provide information regarding your income.
Communications with PlutoInnovations. We may receive Personally Identifiable Information when you send us an email message or otherwise contact us.
Third-Party Sites. We may receive Personally Identifiable Information when you access or log in to a third-party site, e.g., Facebook, from our Sites. This may include the text and/or images of your Personally Identifiable Information available from the third party site.
Surveys. We may receive Personally Identifiable Information when you provide information in response to a survey operated by us. This may include details about your race, your education history, and your employment.
Partner sites. Partner sites providing Online Course-related tools and services to PlutoInnovations users may collect nonfinancial individual-level user data regarding the individual’s use of that partner site while engaged with such Online Course-related activities, and the partner sites may share that data with PlutoInnovations for the purpose of improving PlutoInnovations’s services, the partner site’s services, and the individual’s educational experience. This data includes information such as the amount of time spent on the partner site and pages viewed.
Third-Party Credit Card Processing. PlutoInnovations provides you with the ability to pay for Online Courses and other services using a credit card through a third-party payment processing service provider. Please note that our service provider – not PlutoInnovations – collects and processes your credit card information.

How We Use the Information
1. Information relating to your use of our Site. We use information relating to your use of the Site to build higher quality, more useful services by performing statistical analyses of the collective characteristics and behavior of our users, and by measuring demographics and interests regarding specific areas of our Site. We may also use this information to ensure the security of our services and the Site.

2. Personally Identifiable Information provided directly by you or via third parties. Except as set forth in this Privacy Policy or as specifically agreed to by you, PlutoInnovations will not disclose any of your Personally Identifiable Information. In addition to the other uses set forth in this Privacy Policy, we may disclose and otherwise use Personally Identifiable Information as described below.

Providing the Site and our services. We use Personally Identifiable Information which you provide to us in order to allow you to access and use the Site and in order to provide any information, products, or services that you request from us.
Technical support and security. We may use Personally Identifiable Information to provide technical support to you, where required, and to ensure the security of our services and the Site.
Updates. We use Personally Identifiable Information collected when you sign-up for our various email or update services to send you the messages in connection with the Site or an Online Course. We may also archive this information and/or use it for future communications with you, where we are legally entitled to do so.
Forums. You should not post any Personally Identifiable Information or other information of a personal or sensitive nature, whether relating to you or another person, within a Forum post. If you choose to post Personally Identifiable Information, such Personally Identifiable Information may be collected during your use of the Forums. We may publish this information via extensions of our Platform that use third-party services, like mobile applications. We reserve the right to reuse Forum posts that contain Personally Identifiable Information in future versions of the courses we offer, and to enhance future course offerings. We may archive this information and/or use it for future communications with you and/or your designee(s), and/or provide it to the University partner, business partner, or the instructor(s) associated with the courses you have taken. We may also use or publish posts submitted on the Forums without using Personally Identification Information.
Participation in Online Courses. We use the Personally Identifiable Information that we collect from you when you participate in an Online Course through the Site for processing purposes, including but not limited to tracking attendance, progress, and completion of an Online Course. We may also share your Personally Identifiable Information and your performance in a given Online Course with the instructor or instructors who taught the course, with teaching assistants or other individuals designated by the instructor or instructors to assist with the creation, modification, or operation of the course, and with the institution or institutions with which they are affiliated. Also, we may archive this information and/or use it for future communications with you, where we are legally entitled to do so.
Identity Verification. For services that require identity verification, we use the Personally Identifiable Information that we collect for verifying your identity, and for authenticating that submissions made on the Site were made by you. This service may be provided through a third-party identity verification vendor. Your photo identification document will be deleted after successful verification of your profile information.
Communications with or from PlutoInnovations. When you send us an email message or otherwise contact us, we may use the information provided by you to respond to your communication and/or as described in this Privacy Policy. We may also archive this information and/or use it for future communications with you where we are legally entitled to do so. Where we send you emails, we may track the way that you interact with these emails (such as when you open an email or click on a link inside an email). We use this information for the purposes of optimizing and better tailoring our communications to you.
Communications with PlutoInnovations Business Partners. We may share your Personally Identifiable Information with University partners and other business partners of PlutoInnovations so that PlutoInnovations University partners and other business partners may share information about their products and services that may be of interest to you where they are legally entitled to do so.
Research. We may share general course data (including quiz or assignment submissions, grades, and forum discussions), information about your activity on our Site, and demographic data from surveys operated by us with our University partners and other business partners so that our University partners and other business partners may use the data for research related to online education.
Disclosure to PlutoInnovations Operations and Maintenance Contractors. We use various service providers, vendors, and contractors (collectively, "Contractors") to assist us in providing our products and services to you. Our Contractors may have limited access to your Personally Identifiable Information in the course of providing their products or services to us so that we in turn can provide our products and services to you. These Contractors may include vendors and suppliers that provide us with technology, services, and/or content related to the operation and maintenance of the Site or the Online Course. Access to your Personally Identifiable Information by these contractors is limited to the information reasonably necessary for the contractor to perform its limited function for us.
Government Authorities, Legal Rights and Actions. PlutoInnovations may share your Personally Identifiable Information with various government authorities in response to subpoenas, court orders, or other legal processes; to establish or exercise our legal rights or to protect our property; to defend against legal claims; or as otherwise required by law. In such cases, we reserve the right to raise or waive any legal objection or right available to us. We also may share your Personally Identifiable Information when we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of PlutoInnovations, the Site, our users, customers, or others; and in connection with our Terms of Use and other agreements.
Disclosure to Acquirers. PlutoInnovations may disclose and/or transfer your Personally Identifiable Information to an acquirer, assignee, or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of the equity, business, or assets of PlutoInnovations to which your Personally Identifiable Information relates.
e-Readers. If we receive any Personally Identifiable Information related to the extent to which you use designated e-Readers to access PlutoInnovations materials, we may archive it, and use it for research, business, or other purposes.

External Links For your convenience we may provide links to sites operated by organizations other than PlutoInnovations ("Third Party Sites") that we believe may be of interest to you. We do not disclose your Personally Identifiable Information to these Third Party Sites unless we have a lawful basis on which to do so. We do not endorse and are not responsible for the privacy practices of these Third-Party Sites. If you choose to click on a link to one of these Third-Party Sites, you should review the privacy policy posted on the other site to understand how that Third Party Site collects and uses your Personally Identifiable Information.

Retention of Personally Identifiable Information If you reside or are located in the EEA, we keep your Personally Identifiable Information for no longer than necessary for the purposes for which the Personally Identifiable Information is processed. The length of time we retain Personally Identifiable Information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise, or defend our legal rights.

Confidentiality & Security of Personally Identifiable Information We consider the confidentiality and security of your information to be of the utmost importance. We will use industry-standard physical, technical, and administrative security measures to keep your Personally Identifiable Information confidential and secure and will not share it with third parties, except as otherwise provided in this Privacy Policy, or unless such disclosure is necessary in special cases, such as a physical threat to you or others, as permitted by applicable law. Because the Internet is not a 100% secure environment we cannot guarantee the security of Personally Identifiable Information, and there is some risk that an unauthorized third party may find a way to circumvent our security systems or that transmission of your information over the Internet will be intercepted. It is your responsibility to protect the security of your login information. Please note that e-mails communications are typically not encrypted and should not be considered secure.

Updating or Deleting Your Personally Identifiable Information
You have certain rights in relation to your Personally Identifiable Information. You can access your Personally Identifiable Information and confirm that it remains correct and up-to-date or choose whether or not you wish to receive material from us or some of our partners by logging into the Site and visiting your user account page.
If you would like further information in relation to your rights or would like to exercise any of them, you may also contact us via privacy@PlutoInnovations.org. If you reside or are located in the EEA, you have the right to request that we:

provide access to any Personally Identifiable Information we hold about you;
prevent the processing of your Personally Identifiable Information for direct-marketing purposes;
update any Personally Identifiable Information which is out of date or incorrect;
delete any Personally Identifiable Information which we are holding about you;
restrict the way that we process your Personally Identifiable Information;
provide your Personally Identifiable Information to a third-party provider of services; or
provide you with a copy of any Personally Identifiable Information which we hold about you.

We try to answer every email promptly where possible and provide our response within the time period stated by applicable law. Keep in mind, however, that there will be residual information that will remain within our databases, access logs, and other records, which may or may not contain your Personally Identifiable Information. Please also note that certain Personally Identifiable Information may be exempt from such requests in certain circumstances, which may include if we need to keep processing your Personally Identifiable Information to comply with a legal obligation.
When you email us with a request, we may ask that you provide us with the information necessary to confirm your identity.

Questions, Suggestions, and Complaints If you have any privacy-related questions, suggestions, unresolved problems, or complaints you may contact us via privacy@PlutoInnovations.org.
If you reside or are located in the EEA, our Data Protection Officer and Privacy Team may assist with all queries regarding our processing of Personally Identifiable at security@PlutoInnovations.org.
If you reside or are located in the EEA, you may also make a complaint to our supervisory body for data protection matters (namely the UK Information Commissioner's Office) or seek a remedy through local courts if you believe that your rights have been breached.

California Privacy Rights
Under California’s "Shine the Light" law, California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g. requests made in 2012 will receive information regarding 2011 sharing activities).

To obtain this information, please send an email message to privacy@PlutoInnovations.org with "Request for California Privacy Information" on the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response. Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response.

International Privacy Practices
PlutoInnovations’s Sites are primarily operated and managed on servers located and operated within the United States. In order to provide our products and services to you, we may send and store your Personally Identifiable Information (also commonly referred to as personal data) outside of the country where you reside or are located, including in the United States. Accordingly, if you reside or are located outside of the United States, your Personally Identifiable Information may be transferred outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your Personally Identifiable Information. We are committed to protecting the privacy and confidentiality of Personally Identifiable Information when it is transferred. If you reside or are located within the EEA and such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as you would have within the EEA to the extent feasible under applicable law. We participate in and commit to adhering to the EU-U.S. Privacy Shield Framework when transferring data from the EEA to the United States. Please see our Privacy Shield Policy for further information.

Changing Our Privacy Policy
Please note that we review our privacy practices from time to time and that these practices are subject to change. Any change, update, or modification will be effective immediately upon posting on our Site. We will notify you of any material change to this Privacy Policy by posting a notice on our Site’s homepage for a reasonable period of time following such update, and by changing the effective date (located at the bottom of this page). Be sure to return to this page periodically to ensure familiarity with the most current version of this Privacy Policy.

No Information from Children Under 13
PlutoInnovations strongly believes in protecting the privacy of children. In line with this belief, we do not knowingly collect or maintain Personally Identifiable Information on our Site from persons under 13 years of age, and no part of our Site is directed to persons under 13 years of age. If you are under 13 years of age, then please do not use or access this Site at any time or in any manner. We will take appropriate steps to delete any Personally Identifiable Information of persons less than 13 years of age that has been collected on our Site without verified parental consent upon learning of the existence of such Personally Identifiable Information.

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