Shorelight, LLC and its affiliates (“Shorelight”, “we” or “us”) are committed to protecting your privacy. We have prepared this European Economic Area (“EEA”) and United Kingdom (“UK”) General Data Protection Regulation (“GDPR”) Privacy Notice (“GDPR Notice”) to provide additional notices to supplement the information in our Shorelight Privacy Notice. This GDPR Notice is subject to the Shorelight Privacy Notice and is incorporated by reference as a supplement thereto.
To fully understand how we collect, use, disclose, and process your Personal Information (as defined in the Shorelight Privacy Notice) that we collect in relation to our Services, this GDPR Notice should be read in conjunction with the Shorelight Privacy Notice. Capitalized terms used in this GDPR Notice, which are not otherwise defined, have the meanings assigned to them in the Shorelight Privacy Notice
1. Scope
This GPDR Notice applies to you if you are a natural person and (1) you are located in the EEA or UK, and our Personal Information processing activities are related to offering you our Services or monitoring your behavior (as far as your behavior takes place in the EEA or UK); or (2) we process your Personal Information in the context of the activities of a Shorelight establishment in the EEA or UK.
2. Use of Your Data
To the extent we collect Personal Information from you, as described in the Shorelight Privacy Notice, we use such information for the purposes listed below. We will only process your Personal Information when relying on a valid “legal basis”, as listed below. Note, that in certain circumstances detailed below, we may rely upon more than one legal basis depending on the specific purposes for which we are using your Personal Information.
1
Purpose
To provide the Services, enable you to use its features, for example to participate in blogs, discussions groups and similar forums, to create your account, apply to schools, and improve the overall user experience. We also use your Personal Information to determine if you are eligible for certain products, services or offers, such as rebates or content guides offered to professionals and students for certain courses.
Legal Basis
Performance of a contract; our legitimate interests; consent (particularly if you provide special categories of Personal Information in connection with our Services).
2
Purpose
To communicate with you, including through email, on our Services or via push notifications to your mobile device so that we can provide you with information regarding your account, updates about us, our work, and our community, and make it easier for you to share such information about us with your social networks. We may also send you information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.
Legal Basis
To take steps to enter into a contract with you; performance of a contract or our legitimate interests.
3
Purpose
For payment processing and financial account management.
Legal Basis
Performance of a contract.
4
Purpose
To provide technical and customer support and respond to your comments and questions.
Legal Basis
Performance of a contract or our legitimate interests.
5
Purpose
To analyze how users use the Services using online analytics and advertising tools and other tools to help us understand traffic and usage patterns, improve our Services and know if there are problems with the Services, including associating you with different devices that you may use to access our Services (as described further in our Cookie Notice).
Legal Basis
Consent; or our legitimate interests.
6
Purpose
To provide you with marketing communications and offers for products and services from Shorelight and our partners, including personalized offers based on your usage of our Services or Sites. We may also provide you with additional information that may be of interest, such as study tips for students or teacher guides for professionals. Where required, we will obtain your consent before sending you direct marketing communications. You may opt out of electronic direct marketing communications at any time by following the unsubscribe instructions provided in emails you receive from us.
Legal Basis
Consent; or our legitimate interests.
7
Purpose
For compliance and protection, such as to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity and piracy; protect our, your, or others’ rights, privacy, safety or property (including by making and defending legal claims); enforce our Terms of Service and comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
Legal Basis
Legal obligation; or our legitimate interests.
8
Purpose
To administer surveys, sweepstakes, special events and other promotions.
Legal Basis
Consent; or our legitimate interests.
9
Purpose
For Aggregation. We sometimes aggregate or anonymize Personal Information in a form that does not allow you to be personally identified and use the resulting information for statistical analysis regarding the use of the Services, such as to better understand our customer base, or for other purposes.
Legal Basis
Our legitimate interests.
10
Purpose
For human resources management. If you are a Shorelight employee or contractor, we will process your Personal Information in order to enable, organize, coordinate, monitor, and otherwise manage your work.
Legal Basis
Legal obligation; performance of a contract; or our legitimate interests
Note: If you do not provide us with Personal Information, we may not be able to offer you the Services described herein. At the time we request your Personal Information, we will let you know which Personal Information is required to receive our Services. We also may use your Personal Information in other ways for which we provide specific notice at the time of collection.
3. Recipients of Personal Information
When we process your Personal Information, we may disclose it as described in our Shorelight Privacy Notice. We may also disclose your Personal Information to service providers to perform some of the processing. The following are the categories of service providers who may receive your Personal Information.
1
Category of Recipient
Storage
Categories of Personal Data Handled by Recipient
- Account and Contact Information
- Unique Identifiers
- Government Issued Identifiers
- Account Access Information
- Relationship Information
- Transaction and Interaction Information
- Online & Technical Information
- Audio Visual Information
- Financial Account Information
- Health Information
- Business Customer Data
- Compliance data
2
Category of Recipient
Customer Management Support (CMS)
Categories of Personal Data Handled by Recipient
- Account and Contact Information
- Unique Identifiers
- Account Access Information
- Relationship Information
- Business Customer Data
- Compliance data
3
Category of Recipient
Email, Storage and Word Processing
Categories of Personal Data Handled by Recipient
- Account and Contact Information
- Unique Identifiers
- Government Issued Identifiers
- Account Access Information
- Relationship Information
- Transaction and Interaction Information
- Online & Technical Information
- Audio Visual Information
- Financial Account Information
- Health Information
- Business Customer Data
- Compliance data
4
Category of Recipient
Teleconference Info
Categories of Personal Data Handled by Recipient
- Account and Contact Information
- Audio Visual Information
5
Category of Recipient
Credit Card Processing
Categories of Personal Data Handled by Recipient
- Account and Contact Information
- Unique Identifiers
- Transaction and Interaction Information
4. International Data Transfers
Shorelight is based in the United States and transfers Personal Information to and within the United States. If you provide us with your Personal Information when using the Services from the EEA or UK, then please note that we may transfer your Personal Information to and within the United States. Shorelight and our non-profit Customer Educational Institutions in the United States, to whom we may transfer your Personal Information, are not subject to an adequacy decision by the European Commission. You may contact us for more information about international data transfers using the contact information at the bottom of this GDPR Notice.
5. Your European Privacy Rights
In addition to the rights and choices described in our Shorelight Privacy Notice, you have the additional rights described below:
You may request access to the Personal Information we maintain about you, update and correct inaccuracies in your Personal Information, restrict or object to the processing of your Personal Information, have your Personal Information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your Personal Information to another company. In addition, you also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.
You may withdraw any consent you previously provided to us regarding the processing of your Personal Information, at any time and free of charge. We will apply your preferences going forward, and this will not affect the lawfulness of the processing before you withdrew your consent.
If you would like to exercise any of these rights, please contact us:
Telephone Number: 857-317-2001
Shorelight Privacy Email: privacy@shorelight.com
Before meeting your request, we may ask you to provide reasonable information to verify your identity. Please note that there are exceptions and limitations to each of these rights, and we may have valid legal reasons to refuse your request and will inform you if that is the case.
6. Contact Information
We welcome your comments or questions regarding this GDPR Notice. Please e-mail us at privacy@shorelight.com or contact us at the following address:
Shorelight, LLC
2 Seaport Ln., Suite 500
Boston, MA 02110
Attn: Legal Department