PRIVACY POLICY

This Privacy Policy was last modified on 9 July 2019

Welcome to Occam Education LLC (“Occam”)’s website, https://occam.me (the “Site”).

We understand that it is important for visitors to and users of our Site and/or services provided by Occam through the Site (the “Services”) to know how your personal information is used and shared. We recognize our obligation to keep your information secure and confidential. In making available the Site and/or providing the Services, Occam may collect data from you, including personally identifiable information about you (“Personal Data”). This Privacy Policy (the “Policy”) describes what Personal Data we collect, how we use your Personal Data, and additional policies with respect to your Personal Data. This Policy does not cover third-party services over which we do not have control.

This Policy may be modified at any time and from time to time. The date of the most recent changes or revisions will appear on this page. We will notify you of such changes via email or posting on the Site such modification.

By visiting or using the Site or the Services in any manner, you acknowledge that you accept the Policy and you give your consent that we will collect, use and share your Personal Data as outlined in this Policy. If you do not agree with this Policy in its entirety, please do not use the Site and/or the Services.

If you are a resident of the European Economic Area (“EEA”) or Switzerland, please see the “Users in the EEA or Switzerland” section of this Policy.

INFORMATION COLLECTED BY OCCAM

Occam may collect personally identifiable information from you such as your name, telephone number, postal address, e-mail address, and credit card information, so that we (on our own behalf, or on behalf of third parties) or other third parties can provide you with the products and/or services you request or that you have agreed to receive. For example: we will ask for your name, email address, and certain other information in order to register your account for use of the Site. We will collect your credit card information so that we can process your payment for fees associated with accessing the Site or the Services. During the ordering process, such credit card information is transmitted to Occam and then to third-party credit card processors and card issuers that use your information to process your order. You may always refuse to provide Personal Data, but this may lead to our inability to provide you access to the Site or to the Services.

Occam may also collect information that does not identify you by name when you visit the Site or use the Services, such as your internet protocol (“IP”) address, geo-location, domain name, browser configuration, device type, unique device identifier, the type of operating system you are using, information about you Internet service provider, the time of your visit, whether you are a returning visitor, and any referring website.

Occam may also collect information about you from publicly and commercially available sources, as permitted by law, which we may combine with other information we receive from or about you.

HOW OCCAM USES INFORMATION WE COLLECT FROM USERS

We may use the information you supply to fulfill your requests for products and services, to respond to your inquiries, to administer your account, to provide access to the Site and or our Services, to collect fees, to troubleshoot errors, to meet legal requirements, and to offer other products and services from either us or third parties which may be of interest to you. If you choose to submit comments or other content for posting on the Site, we may publish your name, screen name or such information that you supply.

If you have indicated interest in receiving information directly from a third party, we may provide such third party with information that may include but not be limited to your name, telephone number, postal address and email address. If you decide that you do not wish to receive further communications from such third party, you will need to so notify such third party.

We may use information we collect from and about you to facilitate the delivery of targeted advertising to you on the Site. See "Use of Cookies" below.

We sometimes use information that we or our service providers collect through our use of cookies and other tracking technologies to manage and optimize the Site and/or the Services, including to improve the design, delivery and content of the Site and/or the Services and to enable us to personalize your user experience. We may also use the information we collect in the aggregate to analyze how visitors and/or users use the Site and/or Services or for other purposes, and we may share such aggregated data with third parties. See "Use of Cookies" below.

In addition, Occam may disclose information we maintain (A) if in good faith we believe that such disclosure is necessary to (1) comply with the law or legal process; (2) protect and defend our rights and property; (3) protect against misuse or unauthorized use of the Site and/or the Services; or (4) protect the personal safety, property, or rights of our users or the public, or (B) in connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale.

RETENTION OF INFORMATION

We retain your Personal Data for as long as the information is relevant to our business purposes or until you request that we remove the Personal Data. However, we may be required by certain laws or regulations to retain your Personal Data for as long as such laws and regulation require us to do so.

Users who wish to have their Personal Data deleted from the Site may do so by contacting us at support@occam.me. You are responsible for deleting your Personal Data stored on any third-party website or gateway that you have chosen to use and which is not managed by us.

There may be residual Personal Data that will remain in our database logs and other records. Such residual Personal Data will be deleted according to a fixed schedule.

MODIFICATION OF INFORMATION

If you wish to update any Personal Data provided to us, you may do so through the Site or by contacting us at support@occam.me.

INVITATIONS BY REGISTERED USERS

You can invite other people to become registered users of the Site by sending an invitation email via our automated invitation system. For user verification and user volume purposes, we may store the email addresses that you provide to us though our automated invitation system. We do not sell these email addresses or use them to send any other communication.

SECURITY OF INFORMATION

We use commercially reasonable physical, technical and administrative controls to protect the information we collect online. Please note that since no method of transmission over the Internet, or method of electronic storage, is completely secure, we are unable to guarantee security of your information.

LINKS TO THIRD PARTY SITES

The Site and/or the Services may link to third-party websites and services that are outside of our control. Occam is not responsible for the privacy or security of any information collected by such third-party websites or services. You should review the privacy policies applicable to any such third-party websites or services that you use.

HOW TO UNSUBSCRIBE FROM EMAIL

If you decide that you do not wish to receive email communications from Occam, you may opt-out of receiving further e-mails and other communications by clicking "Unsubscribe" or "Manage my email preferences" in any email.

USE OF COOKIES

Occam and some advertisers, service providers and other third parties that help manage and optimize the Site and/or the Services may place cookies on your computer or mobile device in connection with your use of the Site and/or the Services.

"Cookies" are pieces of information that are placed in a storage place on your computer or mobile device when you visit the Site and/or the Services. Cookies recognize your web browser; they do not contain information that is, in itself, personally identifying unless you have specifically provided such information. While you can disable cookies (follow your web browser's instructions to do so), it may interfere with the proper functioning of the Site and/or the Services. Because an industry-standard Do-Not-Track protocol has not yet been established, our information collection practices on the Site and/or the Services will continue to operate as described in this Privacy Policy regardless of any "Do Not Track" signals that may be sent by certain browsers. However, you may refuse to accept cookies in order to prevent tracking activities. Please note that your web browser may not permit you to block the use of non-cookie tracking technologies, and those browser settings that block cookies may have no effect on such techniques.

Cookies and other tracking technologies are placed on your computer or mobile device to improve the design, delivery and content of the Site and/or the Services and to enable us to personalize your user experience. Cookies help deliver and measure the effectiveness of advertisements, calculate unique site visitors, track usage throughout our site, and make the login process more convenient.

We may use cookies and other tracking technologies to recognize your computer or device and/or to collect and record information about your visits to the Site and/or the Services and other websites, so we can facilitate feature functionality, measure the effectiveness of ads, track page usage and paths followed during visits, and provide advertisements about goods and services we think will be of interest to you based on your usage. We do use some third party services to gather statistics and data about both visitors to the Site and users with Accounts. A couple of services we currently use are NewRelic (https://newrelic.com/termsandconditions/privacy) and Google Analytics (https://policies.google.com/technologies/partner-sites). Sometimes these services will themselves store data about visitors to the Site and users with Accounts. In this case, we frequently do not have full, or sometimes any, access to or control over these advertisers' or service providers' use of cookies or other tracking technologies or how they may be used.

INFORMATION FOR USERS IN EUROPE AND ELSEWHERE OUTSIDE OF THE UNITED STATES

If you use Site and/or the Services outside of the United States, you understand that Occam may collect, process, and store your personal information in the United States and other countries. The laws in the U.S. regarding personal information may be different from the laws of your state or country. Any transfers of personal information will comply with safeguards as required by relevant law. If applicable, you may have a right to claim compensation for damages caused by a breach of relevant data protection laws.

in the European Economic Area ("EEA") and Switzerland

If you are a resident of the EEA or Switzerland, the following information applies with respect to personal data collected through your use of the Site and/or the Services.

PURPOSES OF PROCESSING AND LEGAL BASIS FOR PROCESSING

As explained above, Occam processes personal data in various ways depending upon your use of the Site and/or the Services. We process personal data on the following legal bases: (1) with your consent; (2) as necessary to perform our agreement to provide the Site and/or the Services; and (3) as necessary for our legitimate interests in providing the Site and/or the Services where those interests do not override your fundamental rights and freedom related to data privacy.

RIGHT TO LODGE A COMPLAINT

Users that reside in the EEA or Switzerland have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available here: https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

WITHDRAWING CONSENT

If you wish to withdraw your consent to the use of technologies such as cookies to deliver relevant advertising on the Site and/or the Services and across the Internet, personalize content and perform site analytics, you should disable cookies on your browser by following your web browser's instructions. Once you do so, you will not be able to access the Site and/or the Services unless you subsequently provide your consent for the use of such technologies.

TRANSFERS

Personal information we collect may be transferred to, and stored and processed in, the United States or any other country in which we or our affiliates or subcontractors maintain facilities. Occam will ensure that transfers of personal information to a non-EEA country or an international organization are subject to appropriate safeguards.

YOUR RIGHTS

You are entitled to the rights under Chapter III of the EU General Data Protection Regulation or Section 2 of the Swiss Federal Act on Data Protection with respect to the processing of your personal data, which include the right to access and rectify your personal data and to request erasure of your personal data. To exercise these rights, contact support@occam.me.

CHILDREN UNDER AGE 13 (AND CHILDREN UNDER AGE 16 IN EEA AND SWITZERLAND)

No one under the age of 13 should provide any personally identifiable information to Occam. Occam does not knowingly collect personally identifiable information from children under 13 without verified parental consent. In the event that we learn that we have collected such information from a child under the age of 13 without verification of parental consent, we will delete this information from our database as quickly as possible. If you believe the Site and/or the Services has collected any personally identifiable information about anyone under 13, please contact us at support@occam.me. For residents of the EEA and Switzerland, the provisions of this paragraph apply to children under the age of 16, or, if different, the relevant age of consent that has been set for provision of personally identifiable information in such EEA country.

CALIFORNIA RESIDENTS

Users of the Site who are California residents may request certain information pursuant to California Civil Code Section 1798.83 regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to support@occam.me with "Request for California Privacy Information" in the subject line and in the message.

CONTACT US

If you have any questions about this Policy, you can contact us at support@occam.me.