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Privacy Policy

Please read this privacy policy (this “Policy”) carefully before accessing or using the website located at www.nulu.com (the “Site”). Your use of or access to, or license of information, materials, programming, products, or anything else of use or value on the site constitutes agreement to abide by the terms of use then in effect. If you do not agree to these terms of use, do not use or access the site.


By using this Site, you understand and agree to the terms of this Policy. This Policy applies to all users of the Site, including residents of California. The Site is owned by Nulu, Inc. (“Nulu”) and may be accessed in the United States and abroad. For data protection purposes, Nulu is the controller and, unless otherwise noted, is also the processor of data. Information collected may be stored, processed, accessed, and used in jurisdictions whose privacy laws may be different and less protective than those of your home jurisdiction.

1. WHAT INFORMATION DOES NULU COLLECT FROM OR ABOUT YOU?
When you visit the Site, certain kinds of information, such as your IP address, browser type and language, and access times, may be collected automatically as part of the Site’s operation. We also may collect navigational information, including information about the pages you view, the links you click, and other actions taken in connection with the Site.

We may combine your visit and navigational information with personal information that you provide. You may always choose not to provide personal information, but if you so choose, certain products and services may not be available to you. Personal information (e.g., your first name, your last name, nickname, email, password, gender, organization, organization ID, and class) is collected when you register. Additional personal information (e.g., your credit card number and billing address) may be collected to process transactions or to provide you with products and services (collectively “Personally Identifiable Information”).

While using the Site, we will collect your usage and performance data (“Educational Data”). You will be able to see some of this data on your My Nulu page. We will share your Educational Data with your instructor and administrators at your organization.

2. WHERE DO WE COLLECT INFORMATION FROM YOU AND HOW DO WE USE IT?
Our primary goal in collecting personal information is to provide our visitors with a superior customized online experience. Among other things, we use customer contact information to create accounts, to send promotional emails, to operate and improve the Site, to provide customer service, to perform research and analysis aimed at improving our products, services and technologies, and to display content that is customized to your interests and preferences.

We also use your personal information to communicate with you. We may send transaction-related communications such as welcome letters, billing reminders, and purchase confirmations. We may also send you surveys or marketing communications to inform you of new products or services or other information that may be of interest. If you do not wish to receive marketing communications, you may follow the “unsubscribe” instructions included within each email communication. Please keep in mind that, if you choose not to receive marketing communications, you will continue to receive transactional or account communications (e.g., confirmation emails and account balance statements).

In addition, we may perform statistical analyses of aggregate customer behavior. This allows us to measure relative customer interest in the various areas of the Site for product development purposes and to improve the design of the Site. Any information we collect is used for our own internal purposes to improve the content and navigation of the Site, to enhance users’ experiences when visiting the Site, to customize the content and/or layout of our pages, and to provide the services required by an individual user. We may also use information to notify customers about updates to our Site, to complete user initiated transactions, to trace false orders and to contact consumers directly, or through our third-party service partners, for marketing purposes.

Personal information collected by Nulu may be stored and processed in the United States or any other country in which Nulu or its affiliates, subsidiaries or agents maintain facilities, and by using our sites or services, you consent to any such transfer of information outside of your country. Nulu abides by the safe harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of data from the European Union. If you would like to exercise any of your data protection rights (including the right to have your personal information deleted), please contact us using the “Contact Information” below.

3. WITH WHOM DO WE SHARE YOUR INFORMATION?
Except as otherwise stated in this Policy, we do not sell, trade or rent your Personally Identifiable Information collected on the Site to others.

We may share your personal information to third-party service providers who perform services on our behalf. For example, we may hire other companies to handle the processing of payments, to provide data storage, to host websites, to fulfill orders and shipments, to assist in direct marketing, to conduct audits, etc. Those companies will be permitted to obtain only the personal information they need to provide the service. They are required to maintain the confidentiality of the information and are prohibited from using it for any other purpose.

Information about our customers, including personal information, may be disclosed as part of any merger, acquisition, or sale of the company and/or its assets, as well as in the unlikely event of insolvency, bankruptcy, or receivership, in which personal information would be transferred as one of the business assets of the company. We will notify you of such an occurrence as described in the “Policy Changes” section below.

We reserve the right to disclose your personal information if required to do so by law to the appropriate governmental authorities, or in the good-faith belief that such action is reasonably necessary to comply with legal process, respond to claims, or protect the rights, property or safety of our company, employees, customers, or the public. We will disclose your personal information upon receipt of a court order or subpoena or to cooperate with a law enforcement investigation. We fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful.

4. HOW CAN YOU UPDATE OR CORRECT YOUR PERSONALLY IDENTIFIABLE INFORMATION?
If you would like to review or revise information that you previously provided to us, you may access your information in the “Preferences” section of the Site by clicking on your name at the top of any page. A customer service representative can also assist you in making any changes, as well as in exercising your right to have your personal information corrected or deleted. If you need additional assistance, please contact us at info@nulu.com. You can expect a response from us within ten (10) calendar days. Please be advised that you cannot change your username without re-registering. Please note, that because we keep track of past purchases, you cannot delete information associated with past purchases. Note that we may retain changed or deleted information for archival or other purposes.

5. WHAT SECURITY PRECAUTIONS ARE IN PLACE TO PROTECT AGAINST THE LOSS, MISUSE OR ALTERATION OF YOUR INFORMATION?
The security of your personal information is of utmost important to us. You should be aware that there is always some risk involved in transmitting information over the Internet. We follow generally accepted industry standards to help protect your personal information. We employ reasonable security measures to protect the security of the information you submit to us. For instance, when you enter sensitive information (such as a credit card number) on our registration or order forms, we encrypt that information using secure socket layer (SSL) technology. Our secure servers protect this information using password protection and advanced encryption, and we may use firewall technology for additional protection. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security.

If a password is used to protect your account and personal information, it is your responsibility to keep your password confidential.

6. FORUMS & OTHER INTERACTIVE SERVICES.
The Site may include discussion forums or other interactive areas or services, including blogs, chat rooms, bulletin boards, message boards, online hosting or storage services, or other areas or services in which you or third parties create, post or store any content, messages, comments, materials or other items on the sites (“Interactive Areas”). If you use an Interactive Area, you should be aware that these areas are open to the public and any personal information you post or provide at registration may be viewable by others. We are not responsible for personal information you submit in connection with the Interactive Areas, nor are we responsible for how others might use that information, including sending you unsolicited messages. Submissions to the Interactive Areas do not represent the views of Nulu, or any individual associated with Nulu, and we do not control this content. In no event shall you represent or suggest, directly or indirectly, Nulu’s endorsement of user submissions in the Interactive Areas. Nulu does not vouch for the accuracy or credibility of any content submitted by users in the Interactive Areas, and does not take any responsibility or assume any liability for any actions you may take as a result of reading user published content in the Interactive Areas. Through your use of the Interactive Areas, you may be exposed to content that you may find offensive, objectionable, harmful, inaccurate or deceptive. There may also be risks of dealing with underage persons, people acting under false pretense, international trade issues and foreign nationals. By using the Interactive Areas, you assume all associated risks.

Interactive Area postings may be retained indefinitely. If at any time you would like to remove a posting, please email us at info@nulu.com. Keep in mind that removal of a posting from an Interactive Area does not mean that the posting will be deleted from our systems.

The Site may permit the submission of photos, videos, visual images and other similar content. By submitting your material, for good and valuable consideration, the sufficiency and receipt of which you hereby acknowledge, you hereby grant to Nulu a non-exclusive, perpetual, worldwide license to edit, telecast, rerun, reproduce, use, create derivative works from, syndicate, license, print, sublicense, distribute and otherwise exhibit the materials you submit, or any portion thereof in any manner and in any medium or forum, whether now known or hereafter devised, without payment to you or any third party.

Your submissions are deemed non-confidential and Nulu has no obligation to maintain the confidentiality of any information, in whatever form, contained in any submission.

You represent and warrant to Nulu that you have the full legal right, power and authority to grant to Nulu the license provided for herein, that you own or control the complete exhibition and other rights to the materials you submitted for the purposes contemplated in this license and that neither the materials nor the exercise of the rights granted herein shall infringe upon or violate the right of privacy or right of publicity of, or constitute a libel or slander against, or violate any common law or any other right of, any person or entity.

Users are solely responsible for anything contained in their submissions, message board and/or chat sessions. Nulu does not verify, endorse or otherwise vouch for the contents of any submission, message board or chat room. Users may be held legally liable for the contents of their submissions, message board and chat sessions, and may be held legally liable if their submissions or chat sessions include, for example, material protected by copyright, trademark, patent or trade secret law or other proprietary right without permission of the author or owner, or defamatory comments.

7. COOKIES/CLEAR GIFS.
Like many other commercial sites, the Site utilizes standard technologies called “cookies” and clear GIFs to collect information about how the Site is used. A cookie is a small data text file, which a website stores on your computer’s hard drive (if your web browser permits) that can later be retrieved to identify you to us. Cookies were designed to help a website recognize a user’s browser as a previous visitor and thus save and remember any preferences that may have been set while the user was browsing the site. A cookie cannot be read by a website other than the one that set the cookie. Cookies can securely store a customer’s password, personalize home pages, identify which parts of a site have been visited or keep track of selections, such as those selected in a “shopping cart.” For instance, cookies allow us to prepopulate (or fill in) an email field with your email address if you revisit the Site and place an order. A cookie cannot retrieve any other data from your hard drive, pass on a computer virus, or capture your email address.

We send a cookie to your hard drive when you make an order to record the product name, category of product that you ordered, the amount paid, the order number and any referral codes. No Personally Identifiable Information is recorded. When you click through to the Site from a promotional email, our third-party advertising service partner may send a cookie to your hard drive recording your IP address and other related information.

Clear GIFs: At times, we may work with third-party service partners that employ clear GIFs (also known as pixel tags, single pixel GIFs, web beacons or action tags) for our benefit to help us measure advertising effectiveness. Clear GIFs help us better manage content on the Site by informing us of what content is effective. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of our users. The main difference between the two is that clear GIFs are invisible on the page and are much smaller, about the size of the period at the end of this sentence. Clear GIFs are not tied to your Personally Identifiable Information.

These third-party service partners use clear GIFs: (i) in HTML based emails to let us know which emails have been opened by recipients; (ii) to record when products have been ordered from the Site; and (iii) to track the visitor traffic on the Site. These clear GIFs allow us to measure the usage of each of our Site by our visitors and the effectiveness of certain communications and marketing campaigns. We may also use clear GIFs in a similar manner in our own emails and on the Site.

Clear GIFs can “work with” existing cookies on a computer if they are both from the same website or advertising company. That means, for example, that if a person visited “www.companyX.com”, which uses an advertising company’s clear GIF, the website would match the clear GIFs identifier and the advertising company’s cookie ID number, to show the past online behavior for that computer. This collected information can be shared with the advertising company. We do, at times, provide such information to our third-party advertising service partners, but that information can only be used by our partners for our benefit.

8. CHILDREN, PARENTAL CONSENT AND PRIVACY.
The Children’s Online Privacy Protection Act took effect on April 21, 2000, and imposes certain requirements on sites regarding use by persons under the age of 13. We want to let you know that it currently is our policy not to collect personal information from any person under 13 because children are not permitted to use the Site or services on the Site, and we request that children under the age of 13 not submit any personal information to us via the Site. If we learn that we have inadvertently gathered personal information from a child under the age of 13, we shall attempt to notify such child’s parent or guardian and erase such information from our records, unless the child’s parent or guardian consents to our maintaining such information.

9. YOU SHOULD CAREFULLY REVIEW PRIVACY POLICIES OF ANY THIRD-PARTY SITE ACCESSIBLE FROM THE SITE AND ANY CO-BRANDED SITES NOT COVERED BY THIS POLICY.
We may link to websites, including those of our subsidiaries and third-party content providers that have different privacy policies and practices from those disclosed here. We assume no responsibility for the policies or practices of such linked sites, and encourage you to become acquainted with them prior to use. These other sites may send their own cookies or clear GIFs to users, collect data or solicit Personally Identifiable Information. Additionally, we may have advertising on our Site and these advertisers may collect information about you when you view or click on their advertising through the use of cookies or clear GIFs. We cannot control this collection of information. You should contact these advertisers directly if you have any questions about their use of the information that they collect.

10. TRANSFER OF DATA
The Internet is a global environment. Using the Internet to collect and process personal date necessarily involves the transmission of data on an international basis. When you provide Nulu with Personally Identifiable Information through the Site and we collect your Education Data, the information will be stored on servers located in the United States and possibly other countries. Therefore, by accessing and using the Site and communicating electronically with us, you acknowledge and agree that your Personally Identifiable Information and Education Data may be used, stored and processed in the United States and other countries whose laws may not offer a level of protection of personal information equivalent to those applied in other areas like the European Union.

11. CALIFORNIA PRIVACY LAW
Pursuant to Section 1798.83 of the California Civil Code, residents of California can obtain certain information about the types of personal information that companies with whom they have an established business relationship have shared with third parties for direct marketing purposes during the preceding calendar year. In particular, the law provides that companies must inform consumers about the categories of personal information that have been shared with third parties, the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. To request a copy of the information disclosure provided by Nulu pursuant to Section 1798.83 of the California Civil Code, please contact us via email to info@nulu.com, or by writing us at the following address:

Nulu, Inc.
Attention: Privacy Office
California Customer Choice Notice
101 W Broadway Ste. 200
San Diego, California 92101 USA
Please allow 30 days for a response.

12. POLICY CHANGES.
This Policy was last changed on January 25, 2012. We reserve the right to change the terms of this Policy at any time. If we make changes to any terms or conditions of this Policy, the changes will be posted on this portion of the Site so that you will always know what information we gather, how we might use that information, to whom we will disclose it and what choices you have. Any change, modification, addition or removal of portions of this Policy will be announced on our Site at least ten (10) days before it is implemented. Please be sure to check this page before proceeding to use our Site.  Your continued use of the site once the revised Policy has been posted on the site affirms your agreement to such changes.  Questions regarding this Policy should be directed to info@nulu.com or we may also be contacted directly at the following address:

Nulu, Inc.
Attention: Privacy Office
California Customer Choice Notice
101 W Broadway Ste. 200
San Diego, California 92101 USA

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