Privacy

Drillfly LLC

1. What are Drillfly's practices regarding the collection and use of information?
   
   1. Personally Identifiable Information:
      1. We may collect personally identifiable information from you (including, without limitation, your name and email address) when you provide it to us such as when you create an account, sign-up for a newsletter, participate in a survey, contact customer service or otherwise interact with us.
      2. Subject to 1(b) below, we may use your personally identifiable information in the following ways:
      • To communicate with you and to send your information by email or other means about our services and the like.
      • To help us learn more about your preferences.
      • To help us address problems with and improve our site design, products and services.
      • To enhance your experience with Drillfly;
      • To analyze trends and statistics.
      • To protect the security or integrity of our websites and business.
      • To contact you if necessary.
   2. Information About Children: In order for you to participate in the Drillfly's programs and use our products (the "Programs"), you must register on Drillfly. In all cases, only adults who have active accounts with Drillfly may create accounts for children, which must be sub-accounts within the adults' own accounts.
      1. Information related to children may be used in the following ways:
      • Email addresses may be used to send a confirmation email at registration, as well as information and updates to the Programs.
      • We will also email reports, with further information about the progress a child is making on the Programs.
      • We may use the email addresses as an additional means of communicating with you and your child about Drillfly and the Programs, including notifying you of updates to our Site and related policies.
      • A child's name will be used to customize a child's participation in the Programs, as well as to personalize the reports and updates about the child's progress in the Programs.
      • A parent or teacher's relationship to a child will be used for profile and tracking purposes and to personalize the child's reports.
      • A child's grade level and performance relative to others will be used to assess performance by grade level for Program improvements.
      • Information derived from registration and other sources may be used by us for demographic analysis; in such cases, the information will be aggregated as statistical information.
      • Details Programs you or a child choose will be collected for customer service, marketing and business purposes.
      2. Sometimes Drillfly may collect information directly from a child, over the Internet, or in the form of the interactions that a child makes when participating in the Programs. This includes beginning and ending of lessons, responses a child makes to questions, the timing of responses, a child's choice of character and customizations, and the choice of lessons. This is "Test Data." If we require information directly from a child that is not Test Data we will seek your prior authorization (see "Parental Consent" below), and information about the child's name, identity, address, contact information, personal information, grades, and similar information shall be entered in the registration process only by a parent, teacher or tutor who is an authorized Drillfly account holder. In addition, we may aggregate a child's Test Data with the Test Data of other children participating in the Programs for marketing and other business related purposes. Aggregate information will be anonymous. We will store, access, use and analyze Test Data to:
      • Measure a child's performance in each Program lesson.
      • Adapt the Programs to the child's education needs.
      • Develop testing methods and tests targeted to children.
      • Provide the child, the parent, the teacher, the tutor, or school official with progress reports about a child's performance.
      • Track the performance, efficacy, and participation by teachers, tutors and school officials.
      • Improve the Programs.
      • Conduct statistical analysis using aggregated data.
      • Aggregate the information that we collect from users of our Site to create demographic profiles and performance profiles regarding the progress of children who use the Programs.
      • Share aggregated information with marketing professionals, or potential investors; this aggregated information will be compiled and reported in the form of group statistics only.
   3. Parental Consent: In order to use the Programs, you or your child are asked to submit certain personal information about yourselves and to authorize Drillfly to use that information in a limited number of ways. We ask you or the child ensure that the Parent has reviewed and submitted a Parental Consent as part of the registration process, which will require you to consent to our collection and use of information regarding a child over the Internet as described above.
   4. Passwords: You and your child will be asked to select a password to access the Programs through our Site. This password will be used to allow you and the child to use the Programs. The passwords should be kept confidential. Your password will also allow you to review and change the information we collect about you and a child or children.
   5. Cookies: This Site uses "cookies," which are small data files that are stored on your computer when you visit a website. Cookies enable you to use or shop on this Site and may be used in a variety of ways to enhance or personalize your online experience. For example, we may use cookies to enable you to use certain features of this Site, store your preferences, recognize you when you return to this Site, track your orders, and monitor and maintain information about your use of this Site. Cookies also may be used to collect transaction information needed by promotions conducted on this Site. Cookies do not cause damage to your computer system or files, and only the website that transferred a particular cookie to you can read, modify or delete such cookie. You can set your browser not to accept cookies or to notify you when you are sent a cookie, giving you the opportunity to decide whether or not to accept it. If you do not accept cookies, however, you will not be able to access your account information or make purchases on or similarly use this Site.
   6. Pixel Tags:
      1. We may use "pixel tags" (also called "web beacons" or "clear gifs"), which are tiny graphic images, on this Site and in our emails. Pixel tags help us analyze our customers' online behavior and measure the effectiveness of this Site. We work with service providers that help us track, collect, and analyze this information.
      2. Pixel tags on this Site may be used to collect information about your visit, including the pages you view, the features you use, the links you click, and other actions you take in connection with this Site. This information may include your computer's Internet protocol (IP) address, your browser type, your operating system, date and time information, and other technical information about your computer. We may also track certain information about the identity of the website you visited immediately before coming to this Site. We do not otherwise track any information about your use of other websites.
      3. Pixel tags and cookies in our emails may be used to track your interactions with those messages, such as when you receive, open, or click a link in an email message from us.
   7. Other Information: As you interact with us, certain information my be collected passively, such as your IP address, browser type, operating system, or the MAC address of a wireless device that you may be using to access our Site. This helps us identify you and provide better service to you. An "Internet protocol address" or "IP Address" is a number that is automatically assigned to your computer when you use the Internet. The "MAC Address" or "Media Access Control Address" is an identifier attached to a network adapter, such as your wireless (Wi-Fi) card, device, or component.
2. What are Drillfly's practices regarding sharing and disclosure of Personally Identifiable Information?
   We may share the personally identifiable information that you provide us with the various brands of Drillfly. Additionally, we may share such personally identifiable information with our subsidiaries and affiliates (the "Affiliated Entities") and third parties as follows (per the terms of the below section entitled "How do I opt-out of Drillfly's practice of sharing information with Affiliated Entities and Promotional Partners?", you may opt-out of having Drillfly share your personally identifiable information with Affiliated Entities and such third parties):
   1. Affiliated Entities: We may share your personally identifiable information with Affiliated Entities for the uses set forth above in Section 1(a).
   2. Third Party Promotional Partners: In no event will Drillfly share any individual Test Data with any third party at any time.
   3. Service Providers: We may share your information with our service providers who manage our customer information and perform services on our behalf, such as analyzing certain personal and non-personal information to allow us to better provide products and services to you, sending communications, conducting surveys, etc. We do not authorize any of these service providers to make any other use or disclosure of your information.
   4. Other Disclosures: Personally identifiable information of any individual user also may be shared with other companies outside Drillfly: (A) as permitted by law; (B) in the event of a transfer of ownership or assets of Drillfly; (C) in the event of a bankruptcy of Drillfly; (D) where we determine that disclosure of specific information is necessary to comply with the request of a law enforcement or regulatory agency or other legal process; or (E) to protect the interests or safety of Drillfly or other visitors to this Site.
3. How do I access or change my information?
   
   1. You can review and change certain personally identifiable information related to your use of this Site (such as your name and contact information). To access your information at this Site, simply sign in to your account using your email address and password, and you will be able to edit your personally identifiable information in your account profile.
   2. You can also ask us to update your personally identifiable information by contacting us as described in the section below entitled, "How do I contact you?" Any request to update your personal information may take up to 10 days for your email request and up to 8 weeks for your postal mail request.
4. How do I stop receiving Drillfly emails?
   If you prefer not to receive promotional emails, such as information about new products, special offers and sales events, from one or more of the Drillfly brands, you can let us know by contacting our customer service as described in the below section entitled, "How do I contact you?" Please be sure to include your full name and the email address you used when you registered with or made a purchase from the Drillfly brand. It may take up to 10 days to process your email request.
5. Does Drillfly combine information from different sources?
   We may combine the personally identifiable information that we collect from you with other information about you that we collect or receive from other sources. This information may be used to improve our websites, to personalize your online experience, to tailor our communications with you, and for other internal business purposes.
6. How do I know my personally identifiable information is secure?
   We have in place certain physical, electronic, contractual, and managerial safeguards to protect the security and privacy of your personally identifiable information. No company can fully eliminate security risks connected to handling information on the Internet. You should know that unauthorized persons might attempt to intercept your network communications. We encourage you to exercise caution in accessing Wi-Fi hotspots, other wireless networks and other communications networks.
7. What about links to other websites?
   For your convenience and information, this Site may contain links to other websites, which may have privacy policies that differ from our own. We are not responsible for the content or practices of any linked website. Please be aware that the terms of our Privacy Policy do not apply to these outside websites - we recommend that you review the privacy policy of any website that you access through this Site.
8. How do I contact you?
   For questions about this Privacy Policy, to make choices about receiving promotional communications, to update your personally identifiable information, you can contact any of our Drillfly brands by email, telephone, or postal mail as follows:

   Drillfly LLC
   Attn: Customer Service
   1630 N Main Street, #70
   Walnut Creek, CA 94596-4609
   
   privacy@drillfly.com

9. What laws govern this Privacy Policy?
   
   1. California Law. This Site is controlled and operated by Drillfly from the United States, and is not intended to subject Drillfly or any Affiliated Entity to the laws or jurisdiction of any state, country or territory other than that of the United States. Drillfly does not represent or warrant that this Site, or any part thereof, is appropriate or available for use in any particular jurisdiction. Those who choose to access this Site do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. We may limit this Site's availability, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion. This Site and Privacy Policy are governed by the laws of the State of California, USA, without regard to its choice of law or conflicts of law provisions.
   2. Children's Online Privacy Protection Act. Congress has enacted a law called the Children's Online Privacy Protection Act of 1998 (COPPA) that is designed to protect children's privacy during use of the Internet. Drillfly has implemented practices consistent with the guidelines provided by the Federal Trade Commission. Drillfly will never knowingly request personally identifiable information or private content from anyone under the age of 13 without parental consent. Drillfly does not share children's personally identifiable information with third parties. If you are a parent or legal guardian of a user under 13 you may, at any time, revoke your consent to allow a child to use the Programs under your subscription or account, refuse to allow Drillfly to further use or collect a child's personal information, or direct Drillfly to delete all identifiable information regarding a child that you have provided. To do so, please contact our Privacy Officer at the contact information below. Please note that if you do any of the foregoing, a child will not be able to use the Programs. If you would like more information about COPPA, please go to http://www.ftc.gov/ogc/coppa1.htm
   3. The Children's Internet Protection Act. The Children's Internet Protection Act (CIPA) is a federal law enacted by Congress in December 2000 to address concerns about access to offensive content over the Internet on school and library computers. CIPA imposes certain types of requirements on any school or library that receives funding support for Internet access or internal connections from the "E-rate" program - a program that makes certain technology more affordable for eligible schools and libraries. Each school or library that uses Drillfly's Programs will be responsible for compliance with CIPA. If you would like more information about CIPA, please go to http://www.fcc.gov/cgb/consumerfacts/cipa.html.
   4. The Family Educational Rights and Privacy Act. The Family Educational Rights and Privacy Act (FERPA) is a Federal law that protects the privacy of student education records. The law applies to all schools that receive funds under an applicable program of the U.S. Department of Education. FERPA gives parents certain rights with respect to their children's education records. These rights transfer to the student when he or she reaches the age of 18 or attends a school beyond the high school level. In compliance with FERPA, all student data are stored in ways that are not publicly accessible. Drillfly does not share student information of anyone under the age of 13 with any third parties. If a school requests that student data should be sent to a third party, with parental consent, Drillfly would send the data to the school and never directly to the third party. If you would like more information about FERPA, please go to http://www.ed.gov/policy/gen/guid/fpco/ferpa/index.html.
10. What are the California Privacy Rights?
    California Civil Code Section 1798.83 permits customers of Drillfly who are California residents to request certain information regarding its disclosure of personally identifiable information to third parties for their direct marketing purposes. To make such a request, please write us:

    Drillfly LLC
    Attn: Customer Service
    1630 N Main Street, #70
    Walnut Creek, CA 94596-4609
    
    privacy@drillfly.com

    For additional information, please see:
    http://www.leginfo.ca.gov/cgi-bin/displaycode?section=civ&group=01001-02000&file=1798.80-1798.84
11. How will I know if you update this Privacy Policy?
    We may amend this Privacy Policy at any time. Any such amendment to this Privacy Policy will be effective upon our posting of the revised Privacy Policy on this Site.