KUDER, INC. PRIVACY POLICY

Last Updated: March 5, 2020
 

This Privacy Policy describes how Kuder, Inc. and its subsidiaries (“Kuder”) collect, use, and disclose information that we collect from you, as well as how we protect and secure your data.  If you have additional questions regarding your rights under this Privacy Policy or any agreement you have entered into with Kuder regarding your data, please contact us at privacy@kuder.com.

This Privacy Policy generally applies to Personal Information that Kuder collects, uses, and discloses. However, this Privacy Policy is subordinate to any specific terms and conditions set forth in any terms of use, end user license agreements, or other agreements with Kuder related to a particular product, service, or data that is collected. It is also important to note that your access to products and services from which Kuder collects, uses, and discloses data may be made available through a sponsoring school, governmental agency, or other organization which has contracted with Kuder to offer the product or services to you and collect information relating to you (“Sponsoring Organization”).

Click to view a specific area of the privacy policy…

  1. What Types of Information and Data Does Kuder Collect, and When Does It Collect This Data?
  2. How Kuder Uses Your Information (the "Purposes")
  3. When Will Kuder Disclose Your Information, and Who May Receive It?
  4. How Long Will Kuder Keep your Information?  
  5. Website Data Collection, Cookies, and Similar Technology
  6. Your Choices and Data Control
  7. Information and Data Security
  8. Transfer of Information, Transfers to Other Countries
  9. Privacy Policies of Third Parties
  10. Children’s Privacy
  11. Information We Collect from Children
  12. Information We Collect Directly
  13. Automatic Information Collection and Tracking
  14. How We Use Your Child's Information
  15. Our Practices for Disclosing Children's Information
  16. Accessing and Correcting Your Child's Personal Information
  17. Plug-Ins to Social Media and Other Third Party Services
  18. Amendments and Changes
  19. Your California Privacy Rights
  20. How to Contact Us

What Types of Information and Data Does Kuder Collect, and When Does It Collect This Data?

Kuder collects various types of Personal Information. We collect this information when you provide it to us (whether directly or through our subsidiaries and/or representatives) or when you use certain services provided by Kuder.

"Personal Information" is information that can be used to identify, locate, or contact you as a natural person, as well as other information about you that we tie to Personal Information. Personal Information that we collect includes, but is not limited to, the following types of information:

  • "Contact Information" that allows us to identify and communicate with you, such as your name, phone number, address, email, and language preferences.
  • "Relationship Information" that helps us understand who you are what you want in order to offer you products and services that may interest you, such as demographics such as, race gender, age, household income, grade level, school at which you are enrolled or other organization with which you are affiliated, and other psychographics such information relating to your career planning preferences, interest, or assessments. 
  • "Transactional Information" about how you interact with us, our subsidiaries and Sponsoring Organizations, including services you request, customer service inquiries, and customer account information.

“Non-Personal Information” is any information that does not identify a natural person and is not identifiable to a natural person, such as: 

  • Cookies and other tools used in a non-identifiable way; 
  • Anonymized information; 
  • Aggregated information; and 
  • Information about your business operations, including, but not limited to: 
    • Operation-specific data, such as location data, when kept in a non-identifiable way; and
    • The name, form, and contact details of legal persons.

In addition to the methods described above, Personal Information and Non-Personal Information may be collected by Kuder from its subsidiaries and authorized Sponsoring Organizations as part of its standard business operations, to provide services to the subsidiaries and authorized sponsoring organizations, and as otherwise agreed pursuant to agreements between Kuder and such subsidiaries and authorized Sponsoring Organizations.

When data is described as “anonymized,” it means that the data is no longer associated with a particular person.  When data is described as “aggregated,” it means that such information has been combined with other data in such a way that no person can be identified or linked to any specific action or information.

Back to Top

How Kuder Uses Your Information (the "Purposes")

Subject to the limitations and other rights set forth in this Privacy Policy, Kuder uses your Personal Information in its identifiable form for a variety of purposes, including:

  • To Complete Orders and Provide Requested Services. To fulfill orders for products or services, and for other services or purposes as you may request or direct, such as product delivery, maintenance, and the like. 
  • Product and Customer Support. To provide support services, to deliver upgrades and product improvement communications. 
  • Marketing and Surveys. To communicate offers for products, building content, and services from Kuder or its subsidiaries, dealers, suppliers, partners, or authorized sponsoring organizations, including offers based on your demographics and psychographics, interests, personal and business characteristics and your location; to administer surveys, polls, sweepstakes, contest, loyalty programs and other promotional events; and to provide other information which may be of interest to you, such as Kuder company news, catalogs, announcements, reminders, and technical bulletins. Please contact us if you would not like to be contacted by Kuder for marketing purposes without being asked.  We will provide you with the opportunity to opt-out of marketing information or market research inquiries.  
  • General Business Purposes. To provide and accomplish standard business tasks, such as payment processing, financial account management, product development, contract management, website administration, web-forum management, order or contract fulfillment, analytics, fraud prevention, corporate governance, reporting and legal compliance.
  • As Disclosed at the Time of Collection. In any other manner that we may describe when you provide the information to us. 

These Purposes may be necessary for Kuder to perform a contract to which you are a party, comply with a legal obligation to which Kuder is subject, protect Kuder’s vital interests or the interests of another natural person, or otherwise pursue Kuder’s legitimate business purposes and objectives.  Kuder may obtain your consent to process your Personal Information, as necessary.

Kuder collects Non-Personal Information in the same ways it collects Personal Information, described elsewhere in this Privacy Policy. 

Because Non-Personal Information does not personally identify you, Kuder may use and disclose Non-Personal Information for any purpose. In some instances, Kuder may combine Non-Personal Information with Personal Information (such as combining your name with your location data). If Kuder combines any Non-Personal Information with Personal Information, Kuder will treat the combined information as Personal Information.

In addition, Kuder reserves the right to use anonymized and aggregated Personal Information to improve its products and services, to create and publish reports, to conduct statistical analysis about our customers and products, and for other activities that do not result in the disclosure of your identifiable information.

Back to Top

When Will Kuder Disclose Your Information, and Who May Receive It?

Kuder is committed to being transparent regarding the manner in which we use and disclose your information. We may disclose and share your information as follows:

  • In order to fulfill the purposes of products and services, we may disclose and make accessible to a Sponsoring Organization and its affiliates in accordance with the terms of an agreement between Kuder and such Sponsoring Organization. 
  • We may share Personal Information with our subsidiaries, Sponsoring Organizations,  and business partners, as needed to accomplish, and consistently with, the Purposes set forth above, or as you authorize or request. 
  • We may also share Personal Information with our service providers to fulfill the Purposes on our behalf. Our service providers are bound by law or contract to treat your information and data with the same level of protection that we do and to only use it in accordance with our instructions.
  • We may disclose Personal Information where needed to affect the sale or transfer of business assets, to enforce our rights, protect our property, or protect the rights, property, or safety of others, or as needed to support external auditing, compliance, and corporate governance functions. 
  • We will also disclose Personal Information when required to do so by law, such as in response to a subpoena, including to law enforcement agencies and courts in the countries where we operate.

As noted above, Kuder reserves the right to use and disclose anonymized and aggregated Personal Information to improve its products and services, to create and publish reports, to conduct statistical analysis about our customers and products, and for other activities that do not result in the disclosure of your identifiable information. 

Back to Top

How Long Will Kuder Keep your Information?  

Kuder keeps different kinds of personal data for different lengths of time, depending on the Purposes for which they are processed and the unique circumstances of your situation.  Kuder will hold your Personal Information as long as necessary for the relevant Purpose.  For more information on Kuder’s data-retention policy and how long your data might be retained, please contact us as provided below.  

Back to Top

Website Data Collection, Cookies, and Similar Technology

When you visit our website or use our mobile applications, we collect certain information by automated means, using technologies such as cookies, pixel tags, browser analysis tools, server logs and web beacons.

For example, when you visit our website, we may place cookies on your computer. Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser. Cookies allow us to recognize you when you return. They also help us provide a customized experience and enable us to detect certain kinds of fraud. We may also use Adobe Flash Cookies, Microsoft Silverlight, and similar technologies which remember your settings, preferences, and usage in a manner similar to browser cookies to personalize and enhance your online experience, but which are not managed through your browser. To manage your Flash and Silverlight cookies, please see Adobe’s and Microsoft’s websites.

Pixel tags and web beacons are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, the pixel tags and web beacons generate a notice of that action. These tools allow us to measure the response to our communications and improve our web pages and promotions.

We collect many different types of information from cookies and other technologies. For example, we may collect information about the device you use to access our website, your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. Our server logs also may record the IP address or derivative of the device you use to connect to the Internet. An IP address is a unique identifier that devices use to identify and communicate with each other on the Internet. We may also collect information about the website you were visiting before you came to Kuder and the website you visit after you leave our site.

In many cases, the information we collect using cookies and other tools is only used in a non-identifiable way, without reference to Personal Information. For example, we use the information we collect about website users to optimize our websites and to understand website traffic patterns. In some cases, we do associate the information we collect using cookies and other technology with your Personal Information. Additionally, if the settings on your geo-aware mobile devices permit our mobile applications to collect location information, we will collect that information automatically. This Privacy Policy governs how we use all of this information when we associate it with your Personal Information.

Back to Top

Your Choices and Data Control

You can limit the information you provide to Kuder. You can also limit the communications that Kuder sends to you. To opt-out of marketing emails, you can visit our website and communicate your choice to the relevant privacy contact. Alternatively, you may opt-out of receiving future marketing emails by clicking "unsubscribe" at the bottom of marketing emails we send you.

Please note that even if you opt-out of receiving marketing material, we may still need to contact you with important Transactional Information about your account or your products. For example, even if you opt-out of marketing emails, we will still send you a confirmation when you purchase something from us as well as to provide communications related to our products.

You can manage cookie preferences and opt-out of having cookies and other similar collection technologies used by adjusting the settings on your browser or interface, commonly known as “Do Not Track” settings. All browsers and interfaces are different, so visit the "help" section of your browser or interface to learn about cookie preferences and other privacy settings that may be available. You can manage how your mobile device and mobile browser share location information with Kuder, as well as how your mobile browser handles cookies and related technologies by adjusting your mobile device privacy and security settings. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings. In general, Kuder complies and requests that all of its service providers comply with your “Do Not Track” settings you select using your internet browser(s).

Kuder complies with applicable law regarding your ability to access, correct, and delete your Personal Information. If you have an online account, you may be able to log into your account to access and update certain information you provided to us. For Personal Information that is not linked to an online account, for assisting in opting-out of communications, or if you need assistance updating or deleting your Personal Information, please contact us via email at privacy@kuder.com. You can also write to us at the address in the How to Contact Us section below. If you send us a letter, please provide your name, address, email address, and detailed information about the change you would like to make.

For EU Residents: 

The General Data Protection Regulation (“GDPR”), particularly Articles 15 to 21, affords an EU resident, a number of rights as a data subject.  If you are an EU resident, Kuder encourages you to read and learn about those rights on your own.  However, the following will help you to begin to understand those rights afforded to EU residents.  

  • The Right to Access: This allows you to request from Kuder information about your Personal Information, including what data Kuder has and how and why it is being processed.
  • The Right to Rectification: In the event that some or all of the Personal Information that Kuder has concerning you is inaccurate, this gives you the right to have those inaccuracies rectified.
  • The Right to Erasure: In some cases, you may have the right to request that Kuder erase your Personal Information that it has in its possession.
  • The Right to Restriction of Processing: This gives you the right, in some circumstances, to have Kuder process your Personal Information only with your consent. 
  • The Right to Object to Processing: Where Kuder is processing your Personal Information on the ground of its legitimate interests, or to carry out tasks in the public interest or to exercise official authority, you have a right to object to the processing on grounds relating to your particular situation. In cases where you object to Kuder’s processing of your personal data for direct marketing purposes, the processing will cease. 
  • The Right to Data Portability: This allows you to request from Kuder a copy of your Personal Information that it has on file and to transfer that information to someone else without any interference from Kuder.  In some cases, you may be able to request that Kuder transfer your Personal Information directly to a third party on your behalf.

In addition, to the extent that Kuder processes any of your Personal Information on the basis of your consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing that was based on your consent before its withdrawal.

If you are a natural person residing in the EU and at any time you believe Kuder has violated one of your rights listed above, or if you believe Kuder is in violation of one or more of the provisions of the GDPR, you have the right to lodge a complaint with a Data Protection Authority.  More information about the Data Protection Authorities can be found at https://ec.europa.eu/info/law/law-topic/data-protection/reform/what-are-data-protection-authorities-dpas_en.

Back to Top

Information and Data Security

Kuder has implemented an information and data security program that contains administrative, technical and physical controls that are designed to reasonably safeguard Personal Information.

Back to Top

Transfer of Information, Transfers to Other Countries

Kuder is headquartered in the United States of America. Personal Information may be accessed by or transferred to the United States or to our controlled affiliates and data processors elsewhere in the world for the Purposes described in this Privacy Policy. When we access or transfer Personal Information, we do so in compliance with applicable law. Additionally, we protect the privacy and security of Personal Information in the manner described in this Privacy Policy, regardless of where it is processed or stored.  

Back to Top

Privacy Policies of Third Parties

This Privacy Policy only addresses the collection, use, and disclosure of information and data by Kuder and its subsidiaries. Other websites that may be accessible through this website have their own privacy policies and practices, which govern their use of information that they collect or otherwise obtain from you. Our Sponsoring Organizations and business partners have their own privacy policies and practices as well. We encourage you to familiarize yourself with the privacy statements provided by all such third parties prior to providing them with information or taking advantage of an offer or promotion.

Back to Top

Children’s Privacy

Except in the case of Kuder Galaxy, we do not knowingly collect Personal Data from children under the age of 13. If you are under 18, please be sure to read this section of our Privacy Policy with your parent(s) or legal guardian(s) and ask questions about things you do not understand.

The Children's Online Privacy Protection Act of 1998 and its rules (collectively, "COPPA") require us to inform parents and legal guardians (as used in this section, "parents") about our practices for collecting, using, and disclosing personal information from children under the age of 13 ("children"). It also requires us to obtain verifiable consent from a child's parent for certain collection, use, and disclosure of the child's personal information.

A school may sign up a child for online websites subject to COPPA and then under the provisions of COPPA, the school transfers such consent to Kuder through agreements with schools. This section seeks to provide the relevant notifications under COPPA, including:

  • The types of information we may collect from children.
  • How we use the information we collect.
  • Our practices for disclosing that information.
  • Our practices for notifying and obtaining parents' consent when we collect personal information from children, including how a parent may revoke consent.
  • All operators that collect or maintain information from children through this website and Kuder Galaxy programs.

This section only applies to children under the age of 13 and supplements the other provisions of this privacy policy. Only the other provisions of this privacy policy apply to teens and adults.

Back to Top

Information We Collect from Children

Children can access many parts of the Service and its content and use many of its features without providing us with personal information. However, some content and features are available only to registered users or require us to collect certain information, including personal information, from them. In addition, we use certain technologies, such as cookies, to automatically collect information from our users (including children) when they visit or use the Service.

We only collect as much information about a child as is reasonably necessary for the child to participate in an activity, and we do not condition his or her participation on the disclosure of more personal information than is reasonably necessary.  

Back to Top

Information We Collect Directly. A child must provide us with the following information to register with this website: the child's name, birth date. We also require the child to create a member name and password. We may request additional information from your child, but this information is optional. We specify whether information is required or optional when we request it.

Back to Top

Automatic Information Collection and Tracking. We use technology to automatically collect information from our users, including children, when they access and navigate through the Website/Service and use certain of its features. The information we collect through these technologies may include: 

  • One or more persistent identifiers that can be used to recognize a user over time and across different websites and online services.
  • Information that identifies a device's location (geolocation information).

We also may combine non-personal information we collect through these technologies with personal information about you or your child that we collect online. 

For information about our automatic information collection practices, including how you can opt out of certain information collection, see the "Automatic Information Collection and Tracking" and "Choices About How We Use and Disclose Your Information" sections of this Privacy Policy. 

Back to Top

How We Use Your Child's Information

We use the personal information we collect from your child to: 

  • Register him or her with the Site/Service.
  • Communicate with him or her about activities or features of the Website/Service that may be of interest.
  • Track his or her performance in games or other activities.

We use the information we collect automatically through technology (see Automatic Information Collection and Tracking) and other non-personal information we collect to improve our Website/Service and to deliver a better and more personalized experience by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about the child's preferences, allowing us to customize the content according to individual interests.
  • Speed up your searches.

Back to Top

Our Practices for Disclosing Children's Information

We do not share, sell, rent, or transfer children's personal information other than as described in this section.

We may disclose aggregated information about many of our users, and information that does not identify any individual or device. In addition, we may disclose children's personal information:

  • To third parties we use to support the internal operations of our Website/Service and who are bound by contractual or other obligations to use the information only for such purpose and to keep the information confidential.
  • If we are required to do so by law or legal process, such as to comply with any court order or subpoena or to respond to any government or regulatory request.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Kuder, our customers or others, including to:
  • protect the safety of a child;
  • protect the safety and security of the Website/Service]; or
  • enable us to take precautions against liability.
  • To law enforcement agencies or for an investigation related to public safety.

In addition, if Kuder is involved in a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Kuder's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding or event, we may transfer the personal information we have collected or maintain to the buyer or other successor.

Back to Top

Accessing and Correcting Your Child's Personal Information

At any time, you may review your child's personal information maintained by us, require us to correct or delete your child’s personal information, and/or refuse to permit us from further collecting or using your child's information.

You can review, change, or delete your child's personal information by:

  • Logging into your child's account and visiting his or her account profile page.
  • Sending us an email at privacy@kuder.com. To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections.
  • Contacting your child’s school. 

Back to Top

Plug-Ins to Social Media and Other Third Party Services

In addition, Kuder’s websites may also contain links, plug-ins, APIs (application program interfaces, which simplify the implementation and maintenance of software), and other tools that enable you to share content on our website or your own content through third-party social media or other services (such LinkedIn, Twitter, and other services). All use of such third party services, including through links found on our website, shall be considered public information and shall be subject to the terms and conditions of such third party services.

In addition, Kuder’s websites and software products may incorporate certain mapping software and documentation developed by Google, Inc. and licensed to Kuder. Customer acknowledges and agrees that its use of such mapping software and documentation is subject to Google’s Privacy Policy, which can be found at http://www.google.com/policies/privacy

Back to Top

Amendments and Changes

This Privacy Policy may be amended and updated from time to time to reflect new or different privacy practices. We will place a notice on our homepage when we make material changes to this Privacy Policy. Additionally, if the changes will materially affect the way we use or disclose previously collected Personal Information, we may also notify you about the change by sending an electronic notice to you (if we have your email address).

Back to Top

Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us using the information below.

Back to Top

How to Contact Us

If you have questions or comments about this Privacy Policy or any of our privacy practices, you can contact us at privacy@kuder.com.  You can also reach us via mail at the following address or phone numbers:

Kuder Inc.
Attn: Privacy
302 Visions Parkway
Adel, IA 50003
 

United States Callers: (800) 314-8972

International Callers: +15159933005

Back to Top