Lexia Learning Systems LLC, a Rosetta Stone Company (“Lexia”) is the developer of the Lexia® technology-based learning solutions. We take the privacy of our customers seriously. We are committed to safeguarding your privacy while providing a personalized and valuable service.
Information provided by you may be requested from one of our Websites or those of our affiliates under the Lexia, Rosetta Stone or Rosetta World brand names, or from one of our reputable co-marketing partner sites that represent our brands on their own websites under their company and/or brand name. In the event that you provide us with personal information for the purposes of free registration and you later make a purchase, whether directly from us or facilitated by one of our e-commerce partners, we will collect and use your personal information according to our stated policies that are posted and available for your review at the time of purchase.
2. Information Collected
Personal information is collected by Lexia. We collect personal information about you (your “Personal Information”) through:
- The use of inquiry and registration forms
- The purchase process when you buy any of our products or services
- The provision of your details to us either online or offline
The elements of your Personal Information that we collect under this policy may include:
- Job title
- Company name
- Personal or professional contact and demographic information, shipping and billing addresses, phone and fax number
- Mobile telephone number
- E-mail address
- IP address, device information, activity information and browser information
- Payment details such as credit card information and transaction history
- Market research data such as customer usage patterns
3. Use and Disclosure of Personal Information
Providing our customers with a personalized service and support.
Engaging in transactions and communications with our customers.
Processing orders, registrations and inquiries.
Conducting market research and surveys.
Measuring interest in and improving our website, products, and services.
Providing our customers with information about products and services we offer. You may stop the delivery of marketing emails by following the instructions accompanying a particular communication or by contacting us at firstname.lastname@example.org.
Protecting rights or fulfilling obligations required by law, regulation or contract.
Resolving disputes, collecting fees, protecting against fraud, and troubleshooting problems
We use the information you provide when placing an order to complete that order and to service your account. We do not share this information with outside parties except: 1. to the extent necessary to complete that order or to provide you with services by way of our service providers or contracted partners (e.g., payment processing, sales partners servicing your account, third-party shipping, cloud computing infrastructure and hosting providers, business analytics, customer support); or 2. to successors in title to our business; or 3. in accordance with legal and regulatory requirements or to respond to a government subpoena or other government request; or 4. as necessary, in Lexia’s sole discretion, to protect the perceived rights, safety and property of Lexia, users of our Websites or services, and the public; or 5. with the parent organization, affiliate or subsidiary entities of Lexia to manage the personal information as joint users. We may also disclose your personal information to any other third party with your prior consent.
You may sign-up to receive email or newsletter or other marketing communications from us. If you would like to discontinue receiving this information, you may update your email preferences by using the “Unsubscribe” link found in emails we send to you or at your member profile on our website or by contacting us at email@example.com.
Other than as set out above, you will be notified when personal information about you will be shared with third parties, and you will have an opportunity to choose not to have us share such information.
We also use information in aggregate form (so that no individual user is identified):
- To build up marketing profiles
- To aid strategic development
- To audit usage of the Website
We also use information from cookies for purposes, which may include:
Identifying returning users and registrants
Enabling users to move more easily around our Websites
Tracking how our users use of our Websites to better develop our sites in accordance with user requirements
Building up a demographic profile of our Website users
From time to time we may permit third party companies to set cookies on Lexia Websites for purposes which may include market research, revenue tracking or to improve functionality of the site.
We may place or recognize technology on your browser or device when you visit our Sites for purposes of serving you targeted advertising (also referred to as "online behavioral advertising"). We also work with third party advertising companies who place their own cookies or similar technology on your browser or device when you visit our Sites and other websites to serve customized advertisements to you as you browse the Internet. As noted above, you can set your device or browser to accept or reject most cookies, or at least notify you in most situations that the technology is offered. As an additional step, these advertising companies may participate in one of the following self-regulatory programs for online behavioral advertising, with corresponding user opt-outs:
- Networking Advertising Initiative (http://www.networkadvertising.org/choices/) (US Only)
- Digital Advertising Alliance (http://www.aboutads.info/choices/) (US Only)
- European Interactive Digital Advertising Alliance (http://www.youronlinechoices.eu/) (EU Only)
- Digital Advertising Alliance - Canada (http://youradchoices.ca/choices) (Canada Only)
- DAA App Choices Mobile App (Mobile Devices Only) - For mobile devices (e.g., smartphone, tablets), you may consider downloading the DAA AppChoices Mobile App to manage such technology.
Please note that even if you reject such technology, you may continue to receive advertisements, but the advertisements will not be tailored to your browsing activities and interests.
Lexia has implemented an Information Security Program and security measures designed to help ensure that our users’ Personal Information is protected against unauthorized access or use, alteration, unlawful or accidental destruction, or accidental loss. Although we make reasonable efforts to protect your Personal Information from loss, misuse, or alteration by third parties, you should be aware that there is always some risk involved in transmitting information over the Internet. There is also some risk that thieves could find a way to thwart our security systems. If you have any questions about the security of your personal information, you can contact us at firstname.lastname@example.org.
6. Transfer of Personal Information
The Internet is a global environment. Websites, software, services and programs delivered and accessed through the Internet necessarily involve the transmission and processing of personal data, sometimes on an international basis, depending, for example, on where the user is located. When personal information is provided to Lexia through the Websites, the information will be processed from and stored on servers located in the United States and globally, and by using the Websites, you acknowledge and give Lexia authorization to such transfer, processing and storage.
Lexia participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. Lexia is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov/list.
Lexia is responsible for the processing of personal data it receives under the Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Lexia is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved concern about personal data that we have not addressed satisfactorily, we have committed to cooperate with the panels established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) to serve as our independent dispute resolution bodies for the Frameworks. In addition, under certain conditions, more fully described on the Privacy website, European residents may invoke binding arbitration for non-monetary issues when other dispute resolution procedures have been exhausted.
7. Access to Personal Information & Request Process
Upon request and as provided herein, Lexia will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by contacting us. We will respond to your request within a reasonable timeframe.
Where required by applicable law, and notably by the General Data Protection Regulation (GDPR) for residents of the UK and European Union, you have the right to obtain confirmation of the existence of certain Personal Data relating to you, to verify its content, origin, and accuracy, as well as the right to access, review, port, delete, or to block or withdraw consent to the processing of certain Personal Data (without affecting the lawfulness of processing based on consent before its withdrawal), by contacting us as detailed below. In particular, you have the right to object to our use of Personal Data for any direct marketing and in certain other situations at any time. Please note that certain Personal Data may be retained as required or permitted by applicable law.
If you are a resident of the UK or European Union with questions regarding your rights in Personal Data under GDPR, please contact the Lexia Learning Data Protection Officer, Sofia Simoes, by email at DPO@lexialearning.com.
We may charge the allowable fee under applicable law for provision of this information. We will respond to your request within a reasonable timeframe. Please note that additional information may be required to confirm and enable us to assist with your request. The timeframe to address the request may vary depending on the nature of the request, however, we will endeavor to address the request as promptly as possible, typically within thirty (30) days and as may be required by law.
Notice to California Consumers
This notice is effective as of January 1, 2020
If you reside in California, we are required to provide additional information to you about how we use and disclose your information, and you may have additional rights with regard to how we use your information. We have included this California-specific information below.
- Personal and Other Identifiers or Characteristics: such as first name and last name, personal or professional contacting information, mailing address, telephone number, e-mail address, unique personal identifier, IP, device, and online activity information, age, date of birth, gender, demographics, username and password to our Websites or services;
- Commercial Information: such as payment details, credit card information and purchase or transaction history.
- CA Personal Information Sold or Disclosed For Business Purposes.
- In the preceding twelve months, we may have shared CA Personal Information for business purposes, or we may have “sold” (as defined under CCPA) some categories of CA Personal Information.
If you have questions or concerns regarding your privacy, please contact us by contacting the Privacy Officer at email@example.com or writing to:
Lexia Learning Systems LLC
300 Baker Avenue, Suite 320
Concord Massachusetts 01742
Phone: (978) 405-6200
8. Personal Information – Retention
We may retain your Personal Information for as long as your account is active or as needed to provide you with our services, comply with our legal and regulatory obligations, verify performance, resolve disputes and enforce our rights and agreements.
9. Children Under 13
We do not intentionally collect any information on children under 13 years of age from our Websites. We will undertake to delete any details of such users where a parent, guardian or authorized school official has notified us that any such details have been obtained.
10. Changes to this Policy
Last reviewed: February 3, 2020
Last updated and effective as of: February 3, 2020