Privacy Notice for EU Residents (Last modified: May 24, 2018) 

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Learning Hyperdrive, Inc. ("LH", "we" or "us") owns, operates, or provides access to prepmagic.com ("Website"). This Privacy Notice governs our privacy practices in handling the information we collect about individuals in the EU who use our Website ("you" or "your").

 

LH processes personal data under this Privacy Notice as a data controller. The Contact Details of LH are listed at the end of this Notice. This Notice may be changed if there is a change in the way LH processes personal data or if there is a change in applicable law. We will notify users of changes that are deemed material under applicable law by updating the date of this Notice and providing other information as required.

 

'Personal data' means any information relating to an identified or identifiable natural person ('data subject'). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

 

Categories of Data Obtained Directly from You

 

LH may obtain personal data from you including your first name, last name, email address, organization/school name, and postal address. We collect this information when you:

 

Contact us for information or ask a question. 
Information obtained automatically through technology.

 

The information collected automatically through technology, such as access logs, cookies, pixels and other tracking technologies, may include:
- IP address.
- The domain name of your Internet Service Provider.
- The website, application, platform or service you visited before and after visiting our Website.
- Information about your computer or mobile device, and their browser, operating system, settings and software.
- Unique device identifiers on your mobile device, including as applicable; the Apple or Google advertising identifiers.
- Your approximate geographic location (derived from requested header information, such as your IP address).
- The dates, times, duration and frequency of your interactions with our Website, search terms, the media files (such as images of graphs, etc.) you download, variables value you feed in or by using sliders, or other such interactive elements, bookmarks you select, and your navigation path through our Website.
- Information about your interactions with our email messages.
- Any errors you encountered during your use of the Website.

 

The Website uses third-party analytics, cookie data collection and linking services (collectively "Analytics Website"), including Google Universal Analytics, Google Analytics Demographics and Interest Reporting. These Analytics Website may use cookies, pixel tags, and other tracking and storage technologies to collect or receive information (not including your name or the email address you register with LH) from the Website and elsewhere on the Internet and use that information to analyze and measure LH's audience and target and evaluate the effectiveness of sponsorship credits. We use analytics data, including but not limited to, geographic, demographic, and interest reporting information to recognize and understand user preferences, make improvements, and for other operational purposes. 
Purposes for Processing of Personal Data
LH processes your data in order to:
- Manage, administer, promote, analyze and improve the Website and our communications, including measuring and analyzing user traffic and usage patterns.
- Respond to your questions or messages and fulfill your requests for services.
- Customize the content you see on our Website.
- Recognize you as a returning user as you access our Website using different computers, devices and browsers and to save and "remember" your information, settings and preferences for later visits.
- Send you email newsletters membership and other communications from LH.
- To understand whether and when you read our email messages and click on links in those messages.
- Analyze personal preferences or interests to provide personalized content and messages from LH to control the sequence and frequency of those messages.
- Generate aggregate or other information that does not directly identify you as an individual or the devices you use to access our Website, and use that information for LH's purposes.
- To prevent potentially prohibited or illegal activities, comply with applicable laws, and enforce our Terms of Use and other legal rights.
- We also may use the information collected from you in other ways, and for other purposes, that are described to you at the point of collection or for which we otherwise have obtained your consent.
Sharing Your Personal Data
LH may share your personal data with the following categories of recipients:
- LH's analytics partners such as Google Universal Analytics, Google Analytics Demographics and Interest Reporting.
- If we sell a Service or in the unlikely event of bankruptcy.
- With public authorities when required by law, to respond to subpoenas, court orders, legal process, and other law enforcement measures, and to comply with legal or regulatory obligations.
- With other parties if the information is anonymous and aggregate.
- With other parties if we have disclosed such sharing to you at the time of collection of the information or if we otherwise have your consent.
- Lawful Basis for the Processing of Personal Data.
LH is required to demonstrate a lawful basis for the processing of personal data. LH relies on legitimate interest to process data for the following purposes:
- Data analytics
- Managing user accounts
- Operating, modifying and improving the Website
- Identifying usage trends
- Customizing content and user experience
- Web hosting
- Direct marketing
- Fraud prevention
- Network and information systems security
- To determine the effectiveness of promotional campaigns
- Responding to user questions and requests for information
- Comply with laws and regulations and enforce LH's Terms of Use and other legal rights.
Consent: We process personal data based on your consent to send personalized messages from LH (interest based messages) and to send promotional emails. If you do not consent to the processing or if you do grant consent, you can withdraw your consent at any time by unsubscribing from emails and as described in "Your Rights" below. Please note that all processing of your personal data will cease once you have withdrawn consent but this will not affect any personal data that has already been processed.
Retention: Your personal data is retained no longer than is reasonably necessary to perform the processing described in this Notice and in case of any legal claims or complaints, or as required by law.
Your Rights: Subject to exemptions under applicable law (which may include, depending on the circumstances, U.S. law protecting the rights to free speech and free press or EU law protecting the rights to freedom of expression or information, including processing for journalistic purposes), you have the following rights with respect to your personal data:

- To request a copy of your personal data which LH holds;
- To request that LH provide you access rectify personal data that is inaccurate or out of date;
- To request erasure of your personal data where it is no longer necessary for LH to retain it;
- If you have consented to processing, the right to withdraw consent at any time;
- To request that the data controller provide you with your personal data and where possible, to transmit that data directly to another data controller, where applicable. This right of portability only applies where the processing is based on consent or is necessary for the performance of a contract and if LH processes the data by automated means;
- To request a restriction on further processing where applicable;
- The right to object to processing if the processing is based on legitimate interest, is for direct marketing, or is for scientific/historical research and statistics;
- To lodge a complaint with a supervisory authority.
You may exercise these rights by contacting LH at privacy@learninghyperdrive.com, providing the email address you used to register with LH, and stating your specific request in writing. LH reserves the right to verify your identity and confirm your right to the information. The following options are also available:
To withdraw consent to marketing emails or email newsletters, click the "unsubscribe" link on the email. However, even if you opt out of receiving such communications, we retain the right to send you non-marketing communications (such as information about changes to our Terms of Use or this Notice).
To cancel your LH account, or correct or update your registration information, you may contact us at updateme@prepmagic.com.
To prevent your data from being used by Google Analytics, click here for the Google Universal Analytics opt-out browser add-on: https://tools.google.com/dlpage/gaoptout. To learn more about how Google uses data, visit www.google.com/policies/privacy/partners/.
Transfer of Data Abroad: Because LH operates the Website from the US, your personal data is stored in the US. The territories outside the EEA or Switzerland may not be recognized by the European Commission as ensuring an adequate level of protection pursuant to the GDPR. Where required, data transfers will be made subject to the terms of the applicable EU Standard Contractual Clauses or with your consent. LH will take all steps reasonably necessary to ensure that personal data is treated securely and in accordance with this Privacy Notice in respect of such transfer.
Security: LH employs physical, technical and organizational safeguards to ensure an appropriate level of security for personal data, taking into account the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and security for the rights and freedoms of natural persons.
Automated Decision Making and Analysis: LH and its data analytics vendors analyze user interactions with the Website to create and deliver personalized content to users. This includes tracking user preferences with respect to the interactives accessed, all interaction within the interactives, quizzes created and used, lessons created and used, and search terms in order to derive a user's interests and preferences.
Further Processing: If LH plans to use personal data for a new purpose, it will update this Notice and communicate the changes to individuals before starting any new processing. 
Contact Details:
Data Controller
Learning Hyperdrive, Inc.
15825 Shady Grove Rd, Suite 90
Rockville, MD 20910 USA
privacy@prepmagic.com