Privacy Notice


Last updated: June 4, 2021


PLEASE READ THIS PRIVACY NOTICE CAREFULLY.

If you live in certain countries or states, additional terms may apply to you and can be found at the end of this Privacy Notice (the "Additional Terms"). Additionally, if you are a child or the parent/guardian of a child, additional terms may apply to you or your child and can be found at the Children’s Privacy Notice here. These Additional Terms or Children’s Privacy Notice override the other terms of this Privacy Notice to the extent of any inconsistencies.


Carousel Technologies, Inc. (“Company.”, “we”, “us”, or “our”) respects your privacy as a user (“User,” “you,” or “your”) and is committed to protecting your Personal Data (as defined below) and your right to privacy. If you have any questions or concerns about our notice or our practices with regards to your personal information, please contact us at info@joincarousel.io


This Privacy Notice applies to all information collected through our website or applications, including the “Carousel: SEL for All” app and the “joincarousel.io” website and any related websites or applications which we own or control (collectively, the “Sites” or “Apps”), and/or any related services, sales, marketing, or events we perform (collectively, the "Services"). This Privacy Notice does not apply to any non-affiliated third-party sites or services. 


We take your privacy very seriously. In this Privacy Notice, we seek to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this Privacy Notice that you do not agree with, please discontinue use of our Apps and our Services.


We follow the Children’s Online Privacy Protection Act of 1998 and other applicable laws regarding children. We consider you to be a child if you are not of the legal age to consent to the collection and processing of Personal Data under applicable laws where you live (a “Child”). If you are a Child, you should always check with your parents or guardians before entering information on any website or mobile application. We encourage families to discuss household guidelines regarding the online sharing of personal information. For more information on what you can do as a parent or guardian to control your Child’s access to or use of our Services, please see our Children’s Privacy Notice here.


DO WE MAKE UPDATES TO THIS PRIVACY NOTICE?


In Short: Yes, we will update this notice as we deem necessary.


We may update this Privacy Notice from time to time. The updated version will be indicated by an updated “Last updated” date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.


SUMMARY


  • We are the organization responsible for all your information that is collected and used related to your Personal Data
  • We collect Personal Data from you and from third parties when you use our Services or visit the Apps.
  • We will use your Personal Data for our business purposes, including providing our Services to you, and, with your consent, to provide promotional and marketing materials.
  • We share your information with third parties that provide certain products or services to help us fulfill the Services you request from us, and with your consent, to other parties that provide us with services.
  • We use appropriate safeguards to protect your Personal Data.


WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA?


We are the “data controller” (i.e. the organization responsible for all Personal Data that is collected and used related to you) for the purposes of data privacy laws, principles, and regulations that may apply to you (collectively, "Data Privacy Law"). "Personal Data" has the meaning given in the Data Privacy Law applicable to you, and includes any information or opinion relating to you which allows us to identify you, such as your name, email address, details of products or services you have purchased, and payment details.


WHAT PERSONAL DATA DO WE COLLECT?


In Short: We collect Personal Data in connection with the Services, including information you give us when you purchase Services or visit the Sites.


We collect Personal Data in a variety of ways. When you download, register with, or use the Apps, we may ask, or you may provide information including: 


  1. first name, last name and email address (these are mandatory information which we require when opening a user account on the Apps ("User Account"));
  2. other information necessary for the Services, such as educational information and your role in the Apps (e.g., student or teacher);
  3. optional information used to enhance the Services and for internal analytic purposes (e.g., race, gender, grade)
  4. information you provide about yourself and any preferences in your User Account;
  5. information about your use of the Apps;
  6. communications with us or directed to us via your contact with communications with us;
  7. where you have selected particular services or features on the Sites (e.g. taking a picture), the Apps may ask to access your device’s features (e.g. your device’s camera).

We may also collect your Personal Data from third parties. Some information that we may collect include information on if you log into the platform from a third-party platform (e.g. you access our Services using your Apple or Google account), or Personal Data you give to our service providers so that we can perform the Services you request. Information collected by third party devices or on other sites and services is subject to the privacy policy and practices of the third party providing such site or services and not subject to this Privacy Notice. Please consult the privacy policies of any third party with which you share information in this manner to learn about the third party’s data practices. 


Additionally, during your access and usage of the Apps, we may collect Personal Data from you. This may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.


Personal details including about your nationality or physical or mental health may be considered “sensitive” personal data under applicable Data Privacy Law. We will not process any such data unless you have given your explicit consent, or it is necessary (for instance if you request special assistance), or otherwise in compliance with applicable Data Privacy Law.


HOW DO WE USE YOUR PERSONAL DATA?


In Short: We process your Personal Data for purposes based on your request, to run the Apps and provide our Services, and to achieve certain essential operations.


We use personal information for a variety of business purposes. These purposes may include establishing and maintaining communications with you on various topics, providing you with Services you request, processing and servicing transactions with you, and operating and improving our business and operations. We may also use information we collect for necessary or essential purposes including complying with applicable law and legal processes, detecting and investigating security events, facilitating functionality to our Apps, enforcing the terms of any promotion or giveaway that we run, protecting our rights, and pursuing available remedies for damages we obtain. 


With your consent, or as otherwise permitted by applicable Data Privacy Law, we will use your Personal Data to provide information that we believe is of interest to you, before, during, and after your interactions with us. You can opt-out at any time after you have given your consent to such communications by contacting us at info@joincarousel.io. If you consent, in providing tailored promotional materials to you, we may use the personal information collected through your use of the Apps, such as the user preferences you set and profile data you submit.

We may also use your Personal Data in other ways, and where we do so, we will provide specific notice at the time of collection and obtain your consent unless otherwise permitted by applicable Data Privacy Law.

We will only process your personal data where we have a legal basis to do so, which will depend on the reasons for which we have collected and need to use your Personal Data. 


WHO DO WE SHARE YOUR INFORMATION WITH? 


In Short: We share your information with your consent, to comply with laws, or to provide you with the Services.


We share your information with our personnel, within our company, and to third parties to provide you with the Services and in a manner consistent with this Privacy Notice. This includes other companies and members of the Company, other companies, contractors, or agents that assist us in providing Services, government authorities, law enforcement bodies, and regulators for compliance with legal requirements, or where otherwise required by applicable Data Privacy Law, and other legal and professional advisers in order to enforce our rights in relation to our relationship with you. We will not share your Personal Data with any other third parties without your consent.


As applicable, we will limit sharing of your information in accordance with the choices you have provided us.  


We may use and store your Personal Data in an aggregated and anonymized form so that it is not associated with individuals and does not include personal information. We may use or share information in an anonymized and aggregated manner for many purposes such as research, analysis, modeling, marketing, and advertising, as well as improving our Apps and Services.


If you consent, we may also share your personal information with our partners and other third parties so that they can notify you about products, services, and promotions that might be of interest to you.


We may also transfer your Personal Data to potential buyers in the event that we sell or transfer all or a part of our business or assets (including in the event of a reorganization or dissolution/liquidation), under strict non-disclosure restrictions, and solely in order to allow a buyer to determine whether to proceed with the transaction or where such a determination is made, to complete it. In the case that your Personal Data is sold or transferred pursuant to this section, we will ensure that the recipient of your Personal Data will follow the same privacy practices set forth in this Privacy Notice. 


If we share your Personal Data for any reasons not described in this Privacy Notice, we will inform you before sharing your Personal Data. Except as provided in this Privacy Notice, we will not sell, share, or otherwise transfer your Personal Data to third parties.


IS YOUR PERSONAL DATA TRANSFERRED INTERNATIONALLY?


In Short:  We will transfer, store, and process your information in countries other than your own if you live outside of the United States. You should not access our Apps if you do not agree to the transfer of your data to the United States.


Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information will be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see "WHO DO WE SHARE YOUR PERSONAL DATA WITH?" above) in the United States.


If you are a resident of another country, then we may not have data protection or other laws as comprehensive as those in your country. However, we will take measures to protect your personal information in accordance with this Privacy Notice and applicable law. You may also have additional terms that apply to you and that can be found at the end of this Privacy Notice.  


If you do not wish to be subject to this Privacy Notice, or you do consent to our treatment of your information under applicable law, you should not use the Sites or our Services. 


DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGY?


In Short: Yes, we may use cookies and similar technology to collect information about you and provide the Services to you. However, you may opt-out of non-necessary cookies on our Apps.  

When you visit the Apps, open up electronic communication from us, or interact with us on social media platforms (e.g. Facebook), we may also automatically collect information about you by automated means. In some instances, we may also allow third parties to collect information about you through automated means. Some of these technologies include:


  • Cookies: Cookies are small text files that websites send to internet-connected devices to make your user experience more efficient. Some cookies may exist for a single session and some are persistent for multiple sessions. Some cookies are strictly necessary for the operation of these Apps and some are optional. We may use cookies that are managed by third parties for the purposes explained in this Privacy Notice.
  • Web server logs: Our web servers may collect information on the usage details of your device, including your IP address, operating system, and Apps usage.  
  • Web beacons, pixels, software: We may place items on our Apps or in our electronic communications called “web beacons” or “pixels”. These items help link web pages to particular web servers and their cookies to help us understand our Apps’ traffic. These items may be used to track the pages you view, links that you click, time spent on a page, and other online behavior.  
  • Other: We may use other technology to collect information for the purposes described in this Privacy Notice. These technologies may permit collection of data elements such as browser type, operating system type, IP address, activities conducted on our Apps, and the time and day of your visit. If you visit our website from a mobile device, we collect mobile device information such as data previously mentioned and your location information.


Most web browsers offer settings that allow you to disable or delete cookies. However, if you restrict, disable, or delete cookies, you may not be able to fully use our Apps. If you make this change after you have visited our Apps, you may have to manually delete existing cookies from your electronic device.  

Our Apps may also contain embedded plug-ins, widgets, pixels, or other programming associated with third parties, including external social media platforms. When you encounter these embedded objects, your web browser may establish a direct connection to the third-party services, and in doing so, share information such as your behavior while browsing our Apps, your public profile, and content you have shared.  


We do not currently respond to Do Not Track browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice. 


HOW LONG DO WE KEEP YOUR PERSONAL DATA?


In Short: We keep your Personal data for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your Personal Data for as long as it is necessary for the purposes set out in this Privacy Notice unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). 


When we have no ongoing legitimate business need to process your Personal Data, 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 Data and isolate it from any further processing until deletion is possible. 


HOW DO WE KEEP YOUR PERSONAL DATA SAFE?


In Short: We aim to protect your Personal Data through a system of organizational, physical, and technical security measures.


We have implemented appropriate organizational, physical, and technical organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, the transmission of personal information to and from our Services is at your own risk. You should only access the Sites and the Services within a secure environment.


DO WE COLLECT PERSONAL DATA FROM CHILDREN?


In Short: We may collect data from children, provided that we have obtained verifiable consent from a legal parent or guardian.


We do not knowingly solicit data from or market to children without verifiable parental consent. We consider you to be a child if you are not of the legal age to consent to the collection and processing of Personal Data under applicable laws where you live (a “Child”). If you are a Child, we must get verifiable parental consent before using any of our Apps. Our Children’s Privacy Notice can be found here and governs our collection and use of a Child’s Personal Data.


If we learn that we have collected Personal Data from a child without parental consent, we will take reasonable measures to promptly delete such data from our records and prohibit any user from using our Services or immediately seek parental consent for the collection. If you become aware of any data we have collected from children, please contact us at info@joincarousel.io.


WHAT ARE YOUR PRIVACY RIGHTS?


In Short: You may reject or remove cookies and other tracking technology, as your browsers permits. Also, to the extent you have subscribed to marketing and promotional communications, you may unsubscribe at any time.


Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. You may also reject any non-necessary cookies by using our cookie tool, available when you first access the Apps. Your browser may also allow you to clear your browser web storage.


To the extent that you have subscribed to any marketing and promotional communication, you may unsubscribe at any time from our marketing and promotional communications by following the “Unsubscribe” link in the communication. If you would like to unsubscribe from all communications, please contact us at info@joincarousel.io. We will do our best to respond promptly to any request. You may re-subscribe or sign up for new marketing or promotional communications by signing up to receive them again.


HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

 

If you have questions or comments about this notice, you may email us at info@joincarousel.io or by post to: 

Carousel Technologies, Inc. 

Attn: Privacy 

PO Box 18477

Denver, CO 80218 United States  


ADDITIONAL TERMS


If you live in one of the following countries or states, these Additional Terms apply and override any inconsistent terms in the Privacy Notice:


1. CALIFORNIA, UNITED STATES OF AMERICA


1.1 DATE REVIEWED.


The Privacy Notice and this California section of the Additional Terms were last reviewed on June 4, 2021.


1.2 THE CALIFORNIA CONSUMER PRIVACY ACT.


The provisions in this California section of the Additional Terms are intended to fulfill the requirements of the California Consumer Privacy Act ("CCPA") and shall apply to Users who are residents in California.


1.3 PERSONAL DATA.

To the extent that any terms used in this Privacy Notice and this California section of the Additional Terms are defined in the CCPA, such definitions shall apply. The term "Personal Data" as used in this Privacy Notice and this California section of the Additional Terms shall include "Personal Information" as such term is defined in the CCPA. 


1.4 CATEGORIES OF PERSONAL DATA.


The categories of Personal Data collected by us in the last 12 months are described in WHAT DATA DO WE COLLECT section of the Privacy Notice and, for the purposes of the CCPA, correspond to the following categories of Personal Information listed in the CCPA:


  1. identifiers and personal information categories referenced in applicable California law (first and last names, email address, telephone number, Ip Address, unique identifiers);
  2. protected classification characteristics under California or US federal law (age, gender, race);
  3. commercial information (preferences and attributes, such as likes, updates, and references to presence on the Services)
  4. internet or other similar network activity (information about your use of the Apps and your IP address, including information collected automatically through cookies and the Apps, device attributes); 
  5. geo-location data where the IP address of your computer or device is used to determine your geographic location so that we can customize your experience on the Apps (e.g. language settings);
  6. sensory data, including audio, electronic, visual, thermal, or olfactory information (e.g. your photos where you have selected particular services or features on the Apps); and
  7. inferences drawn from other Personal Data (information you provide about yourself and any preferences in your User Account, communications with us or directed to us via emails).


We collect Personal Data from the following sources:


  1. Directly from you (information provided when you register for our services, correspond with use, etc.);
  2. Automatically collected information (information collected automatically through cookies and other online tracking technologies);
  3. Business partners (analytic companies);
  4. Third Parties; and 
  5. Inferences from your profile or App behavior.


1.5 PROCESSING PERSONAL DATA.


We will not process your Personal Data for purposes which are materially different, unrelated, or incompatible with the purposes set out in the Privacy Notice without providing you notice.


1.6 DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES.


In the last 12 months, to the extent that we have your Personal Data listed in paragraph 1.4 above, we have only disclosed this Personal Data to third parties for business purposes. Third parties that we have disclosed your Personal Data to include service providers and other third parties with whom you or your agents authorize to disclose your personal information in connection with the Services.  


1.7 SALE OF PERSONAL DATA TO THIRD PARTIES.


In the last 12 months, we have not sold your Personal Data to third parties for commercial purposes or for monetary value.


1.8 ADDITIONAL RIGHTS UNDER THE CCPA.


  1. Users who are resident in California may have the following rights under the CCPA in addition to the rights set out in the Privacy Notice:
  2. Access: Once we receive and confirm your verifiable consumer request, we will disclose the following to you:
  3. the categories of your Personal Data and the specific Personal Data that we have collected;
  4. the categories of sources from which your Personal Data was collected;
  5. our business or commercial purpose for collecting your Personal Data; and
  6. the categories of third parties with whom we share your Personal Data, and where such third parties received your Personal Data from us for a business purpose, the categories of your Personal Data that we disclosed to such third parties.


Under the CCPA, you are only entitled to exercise the Personal Data access right set out in this paragraph 1.8(a)(i) twice a year.


  1. Deletion: Once we receive and confirm your verifiable consumer request, we will (and will direct our service providers to whom we have disclosed your Personal Data to) delete your Personal Data unless an exception under the CCPA applies.
  2. The rights set out in paragraph 1.8(a) do not apply to Personal Data collected from our employees as part of their employment with us or Personal Data collected as part of a business-to-business transaction.
  3. To exercise any of the rights set out in paragraph 1.8(a), please contact our team using the contact details set in forth in the Privacy Notice.
  4. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Data. We may need to request specific information from you to help us confirm that your request is a verifiable consumer request.


1.9 NON-DISCRIMINATION.  


We will not discriminate against you for exercising any of your rights under the CCPA. Specifically, unless permitted by the CCPA, we will not:


  1. deny you access to services provided by us on the Apps;
  2. charge you different prices or rates for the goods and/or services provided by us on the Apps, or imposing penalties on you;
  3. provide you with a different level or quality of goods and/or services than otherwise generally provided by us on the Apps; or
  4. suggest that you will receive a different price or rate for, or a different level or quality of, the goods and/or services generally provided by us on the Apps.


1.10 DO NOT TRACK.


To the extent it is applicable, we do not respond to “Do Not Track” requests or signals.