Privacy

This Privacy Policy (the "Privacy Policy") describes how Connecting Global Co., Ltd. d/b/a ScoreNexus (the "Company"), together with its affiliates ("we," "our" or "us") collect, use, and share information in connection with your use of our websites (including scorenexus.com and its subdomains), services, and applications (collectively, the "Services").

We may collect and receive information about you and other users of our Services ("users," "you," or "your") from various sources, including: (a) directly from you when you register for a user account (your "Account") for the Services; (b) indirectly from you when you use the Services; and (c) from third-party websites, services, and partners.

We recommend that you read this Privacy Policy in full to ensure you are fully informed. If you have any questions about this Privacy Policy or about our data collection, use, and disclosure practices, please contact us here.

1.Information We Collect

1.1Information You Provide

Account Registration. When you register for an Account, we may ask for your contact information, including items such as your name, nickname and email address. If you choose to refer a friend to our Services, we may also collect your friend’s name and email address so that we may send them a referral or promotional code to sign up for our Services.

Payment Information. When you make a purchase through our Services, you are directed to our third-party payment processor. We do not store your financial account information on our systems; however, we have access to, and may retain, purchaser information through our third-party payment processor.

Communications. If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide. We may also receive a confirmation when you open an email from us.

1.2Information We Collect When You Use Our Services.

Cookies and Other Tracking Technologies. As is true of most websites, we gather certain information automatically and store it. In addition, when you use our Services, we may collect certain information automatically from your computer or device. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, clickstream data, landing page, and referring URL. To collect this information, a cookie may be set on your computer or device when you visit our Services. Cookies contain a small amount of information that allows our web servers or our third-party services to recognize you. We store information that we collect through cookies, database entries, and/or clear gifs to record your preferences. We may also automatically collect information about your use of features of our Services, about the functionality of our Services, frequency of visits, and other information related to your interactions with the Services. We may track your use across different websites and services. In some countries, including countries in the European Economic Area ("EEA"), the information referenced above in this paragraph may be considered personal information under applicable data protection laws. (More details below under Section 9.)

Usage of our Services. When you use our Services, we may collect information about your engagement with our online practice test platform, such as when you begin, finish or pause a test, answer questions, finish a section, grade a student response or view a score report. Further, we may collect information about your navigation of our Services, and about system-level metrics. We use this data to operate the Services, maintain and improve the performance and utilization of the Services, develop new features, protect the security and safety of our Services and our customers, and provide customer support. We also use this data to develop aggregate analysis and business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of our business.

1.3Information We Receive from Third Parties.

Third-Party Accounts. If you choose to link our Services to a third-party account, we will receive information about that account, such as your authentication token from the third-party account, to authorize linking. If you wish to limit the information available to us, you should visit the privacy settings of your third-party accounts to learn about your options.

Third-Party Partners. We may also receive publicly available information about you from our third-party partners and combine it with data that we have about you.

2.How We Use Information

We use the information we collect in various ways, including to:

  • provide, operate, and maintain our Services;
  • improve, personalize, and expand our Services;
  • understand and analyze how you use our Services;
  • develop new products, services, features, and functionality;
  • communicate with you (either directly or through one of our partners) in order to provide customer service, to provide updates and other information relating to the Services, or to market or promote our Services;
  • process your transactions;
  • send you notifications and other communications about the Services;
  • find and prevent fraud; and
  • comply and enforce applicable regulations and agreements, including enforcing our Terms of Service, or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.

3.How We Share Information

We may share the information we collect in various ways, including the following:

  • Vendors and Service Providers. We may share information with third-party vendors and service providers that provide services on our behalf in order to allow them to assist us in (a) providing our Services, (b) promoting and/or marketing our Services or other services or products, and (c) providing you with information, such as product announcements, software updates, special offers, or other information;
  • Aggregate Information. Where legally permissible, we may use and share information about users with our partners in aggregated or de-identified form that cannot reasonably be used to identify you;
  • Advertising. We work with third-party advertising partners to show you ads that we think may interest you. These advertising partners may set and access their own cookies, pixel tags, and similar technologies on our Services, and they may otherwise collect or have access to information about you which they may collect over time and across different online services. Some of our advertising partners are members of the Network Advertising Initiative or the Digital Advertising Alliance. To learn more about these programs, or opt-out of personalized ads, visit the Digital Advertising Alliance’s Self-Regulatory program for Online Behavioral Advertising at aboutads.info, or the Network Advertising Initiative at networkadvertising.org;
  • Third-Party Partners. We also share information about users with third-party partners in order to receive additional publicly-available information about you;
  • Information We Share When You Sign Up Through a Referral. If you sign up for our Services through a referral from a friend, we may share information with your referrer to let them know that you used their referral to sign up for our Services;
  • Analytics. We use analytics providers such as Google Analytics. Google Analytics uses cookies to collect non-identifying information. Google provides some additional privacy options regarding its Analytics cookies here
  • Business Transfers. Information may be disclosed and otherwise transferred to any potential acquirer, successor, or assignee as part of any proposed merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets;
  • As Required By Law and Similar Disclosures. We may also share information to (a) satisfy any applicable law, regulation, legal process, or governmental request; (b) enforce this Privacy Policy and our Terms of Service, including investigation of potential violations hereof or thereof; (c) detect, prevent, or otherwise address fraud, security, or technical issues; (d) respond to your requests; or (e) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention;
  • With Your Consent. We may share information with your consent.

4.Legal Basis for Using Personal Information

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we normally collect and use your personal information only when doing so (a) is needed in order to perform our contractual or legal obligations to you; (b) is in our legitimate interests and not overridden by your rights; or (c) is done with your consent. We have a legitimate interest in operating our Services and communicating with you as necessary to provide these Services, for example when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities.

If we ask you to provide personal information to comply with a legal requirement or to perform our contractual obligations with you, we will make this clear at the relevant time and will advise you whether the provision of your personal information is mandatory, which includes the possible consequences of not providing your personal information.

5.Third-party Services

You may access other third-party services through the Services, for example, by clicking on links to those third-party services from within the Services. We are not responsible for the privacy policies and/or practices of these third-party services, and we encourage you to carefully review the privacy policies and the terms of service of the parties providing those services.

6.Security

The Company is committed to protecting your information. To do so, we employ a variety of security technologies and measures designed to protect information from unauthorized access, use, or disclosure. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. However, please bear in mind that no services accessible by the Internet can be guaranteed to be 100% secure.

7.Data Retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax, or accounting requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8.Access

If you are a registered user, you may access certain information associated with your Account by logging into our Services. If you terminate your Account, any public activity on your Account prior to deletion may remain stored on our servers and may remain accessible to the public.

To protect your privacy and security, we may also take reasonable steps to verify your identity before updating or removing your information. The information you provide us may be archived or stored periodically by us according to backup processes conducted in the ordinary course of business for disaster recovery purposes. Your ability to access and correct your information may be temporarily limited in cases in which access and correction could (a) inhibit the Company's ability to comply with a legal obligation; (b) inhibit the Company's ability to investigate, make or defend legal claims; (c) result in disclosure of personal information about a third party; or (d) result in breach of a contract or disclosure of trade secrets or other proprietary business information belonging to the Company or a third party.

9.Your Data Protection Rights Under the General Data Protection Regulation ("GDPR")

9.1If you are a resident of the EEA, you have the following data protection rights:

  • If you wish to access, correct, update, or request deletion of your personal information, you can do so at any time by contacting us here. In addition, you can object to the processing of your personal information, ask us to restrict the processing of your personal information, or request portability of your personal information. Again, you can exercise these rights by contacting us here.
  • You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the marketing emails we send you. To opt-out of other forms of marketing, please inform us by contacting us here.
  • Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing of personal information we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

9.2We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

10.Your Choices

10.1You can use some of the features of the Services without registering, thereby limiting the type of information that we collect.

10.2You may unsubscribe from receiving certain promotional emails from us. If you wish to do so, simply follow the instructions found at the end of the email. Even if you unsubscribe, we may still contact you for informational, transactional, account-related, or similar purposes.

10.3Many browsers have an option for disabling cookies, which may prevent your browser from accepting new cookies or enable selective use of cookies. Please note that, if you choose not to accept cookies, some features of our Services may no longer work for you. Further, you might continue to receive advertising material that is not tailored to your interests.

11.Children's Privacy

The Company does not knowingly collect information from children under the age of 13, and children under 13 are prohibited from using our Services. If you learn that a child has provided us with personal information in violation of this Privacy Policy, you can alert us by contacting us here.

12.Changes to this Privacy Policy

This Privacy Policy may be modified from time to time, so please review it frequently. Changes to this Privacy Policy will be posted on our websites. If we materially change the ways in which we use or share personal information previously collected from you through our Services, we will notify you through our Services, by email, or through other means of communication.

13.International Data Transfers

The Company does business globally. We may transfer personal information to countries other than the country in which the data was originally collected. These countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your personal information to other countries, we will protect that information as described in this Privacy Policy.

14.Additional Disclosures for California Residents

In accordance with the California Consumer Privacy Act (the "CCPA"), we are providing additional notices to individuals residing in California from whom we collect "Personal Information" (as defined by the CCPA).

14.1Sale of Personal Information. We do not sell any Personal Information under any category under the CCPA.

14.2Information Collected and Disclosed. In the preceding twelve months, we have collected and/or disclosed for a Business Purpose (as defined by the CCPA) Personal Information under the following CCPA categories:

  • Identifiers (examples: name, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers);
  • Categories of Personal Information in Cal. Civ. Code 1798.80(e) (examples: name, credit card number, debit card number, or any other financial information);
  • Commercial Information (examples: records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
  • Internet or Other Electronic Network Activity Information (examples: Internet browsing information, search history, Internet Protocol address, including the general location associated with such, and information regarding a consumer’s interaction with an internet website, application or advertisement);
  • Inferences Drawn from Personal Information (examples: consumer profiles reflecting a consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes);

14.3Use of Personal Information. The CCPA defines various business and commercial purposes for collecting, using, and disclosing Personal Information. We collect, use, and disclose Personal Information pursuant to the Privacy Policy as is reasonably necessary and proportionate to achieve the following business and operational purposes:

  • Auditing related to current interactions with consumers and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
  • Debugging to identify and repair errors that impair existing intended functionality;
  • Short-term, transient use, including the contextual customization of ads;
  • Contracting with service providers to perform services on behalf of the Company, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the Company;
  • Undertaking internal research for technological development and demonstration;
  • Undertaking activities to verify or maintain the quality or safety of the Services, and to improve, upgrade, or enhance the Services;
  • Otherwise enabling or effecting, directly or indirectly, a commercial transaction;
  • For other purposes for which we provide specific notice at the time the information is collected.

14.4Collection and Disclosure of Personal Information. In the preceding twelve months since this notice was last updated, we have collected Personal Information from sources including directly from you, your use of our services, your devices, our affiliates, our vendors, and our service providers. More specific information about Personal Information we collect is laid out in this Privacy Policy, which we update from time to time.

14.5Sharing of Personal Information. We share your Personal Information with the following categories of CCPA third parties:

  • Affiliates;
  • Vendors and service providers, including for data analytics and marketing and advertising our products and services to you;
  • Third parties integrated into our services;
  • Third parties as required by law and similar disclosures;
  • Third parties in connection with a merger, sale, or asset transfer; and
  • Other third parties for whom we have obtained your permission to disclose your Personal Information.

14.6Your California Privacy Rights. If you are a California resident, you may exercise the following rights:

  • Right to Know and Access. You may submit a verifiable request for information regarding the: (a) categories of Personal Information collected or disclosed by us; (b) purposes for which categories of Personal Information are collected by us; (c) categories of sources from which we collect Personal Information; and (d) specific pieces of Personal Information we have collected about you during the past twelve months;
  • Right to Delete. Subject to certain exceptions, you have the option to delete Personal Information about you that we have collected from you;
  • Verification. Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations;
  • Right to Equal Service and Price. You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations;
  • Shine the Light. We do not rent, sell, or share your Personal Information with non-affiliated companies for their direct marketing purposes, unless we have your permission; and
  • Submit Requests. To exercise your rights under the CCPA, you can deactivate and purge your account, by contacting us here.

15.Contact Us

The data controller of your personal information is the Company. If you have any questions or concerns about this Privacy Policy, please feel free to contact us here.

Last updated: March 23, 2020