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Klett World Languages Learning Platform Privacy Policy

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Klett World Languages Learning Platform – Privacy Policy

Last Updated: November 12, 2023

1. Introduction

Klett World Languages, Inc. (together with its subsidiaries, divisions, and brands, collectively, the “Company,” “us,” “we,” or “our,” as the context may require) operates and provides the Klett World Languages Learning Platform website at https://klettlp.com (the “Site“) along with the Klett World Languages Learning Platform mobile device application (the “App“). This Privacy Policy (this “Policy“) describes our privacy practices for the Site and the App (together, the “Services“), including the types of information we may collect from you when you visit or use the Services and our practices for collecting, using, protecting, and disclosing that information. We respect the privacy of the users of the Services (“you” or “your,” as the context may require) and we are committed to protecting your privacy and the security of your personal information through compliance with this Policy.

Please read this Policy carefully to understand our practices regarding your personal information. By accessing or using the Services, you agree to this Policy and our Terms of Use. If you do not agree with our policies and practices, please do not visit, access, use, or otherwise interact with the Services.

2. Authorization

If you are a student in primary or secondary school or if you are under 18 years old and not sure whether you are old enough to agree to this Policy, please do not use the Services, unless your parent or legal guardian set up your account, registered you to use the Services, or otherwise consented to your setting up an account or registering to use the Services.

The Company receives authorization to collect, use, and disclose personal information of a user in primary or secondary school or a user under 18 years old when an educational agency or institution (as that term is defined in the Family Education Rights and Privacy Act) (“School“), parent, or legal guardian (a) purchases the Services for such user; (b) establishes an account for such user; (c) registers such user to use the Services; or (d) instructs such user to establish an account or register to use the Services. The Company will not collect, use, or disclose personal information of a user under 13 years old without verifiable parental consent, and the Company limits the ways it collects, uses, and discloses personal information that constitutes educational information. For additional information see Section 11 (Children’s Privacy) and Section 12 (Student’s Privacy).

The Company otherwise receives authorization to collect, use, and disclose personal information under this Policy when a user (a) purchases the Services; (b) establishes an account or registers to use the Services; or (c) uses the Services.

3. The Interactions this Policy Covers

This Policy describes and applies exclusively to personal information (as defined below) that we collect on or in connection with the Services and in texts, emails, and other electronic communications sent through or in connection with the Services. Except as otherwise provided in this Policy or as required by applicable law, this Policy does not apply to information that is collected by any application, website, or third party other than the Services, including through any application or content that may access, be linked to, or otherwise be accessible from the Services. If you visit an application, website, or third party that we mention or link to, be sure to review its privacy policy before providing it with any information, as that privacy policy will apply to your interactions with that application, website, or third party.

Except as otherwise provided in this Policy, “personal information” is information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. “Personal information” does not include information which is generally not considered “personal information” under applicable law or is otherwise exempted under applicable law, such as information which is publicly available or subject to special data privacy laws and/or regulations, or information not otherwise considered “personal information” under applicable law.

4. Information We Collect

We collect several types of information from and about you as a result of your use of or registration with the Services and as a result of your communication with us. This information may include:

Various categories of personal information, such as:
- Identifiers, including your name, username, age, physical address, email address, phone number, and other similar identifiers.
- Education information, including grade, course information, class lists, and other records maintained by a School and directly related to a student.
- Location information, to the extent it can be approximately derived from your IP address.
- Professional or employment information, such as the school you currently work for, and also education and work history when you apply to work with us.
- Inferences drawn from any of the above.
- Any other personal information that you upload or share to or on the Services, or which you otherwise provide directly to us.
Information that is about you but individually does not identify you, such as information which has been de-identified or aggregated in a manner where it can no longer be used to identify you.
Information about your internet connection and the equipment you use to access the Services; IP address, approximate location, and other unique device identifiers; your activity on the Services; and other usage details collected through your use of the Services.
Any other information, including personal information, which you disclose or share.

5. How We Collect Personal Information

We may collect personal information:

Directly from you when you provide it to us;
Directly from your School, parent, or legal guardian; and
Automatically when you use or access the Services.

A. Information We Collect Directly

The personal information we collect directly from you when you use or access the Services includes:

Information that you provide by filling in forms on the Services. This includes information provided at the time of requesting further information or reporting a problem with the Services.
User profile information provided at the time of registering to use the Services and throughout the period when you are logged into the Services.
Your voluntary responses to surveys that we might ask you to complete.
Details of transactions you carry out through the Services and of the fulfillment of your orders.
Your search queries on the Services.
Records and copies of your communications when you contact us.

If you are a student, we may also collect information about you directly from your School, parent, or legal guardian, such as when they register you to use the Services.

B. Information We Collect Automatically

As you navigate through and interact with the Services, we may use automatic data collection technologies to collect certain information, including:

Usage details. When you access and use the Services, we may automatically collect certain details of your access to and use of the Services, including traffic data, approximate location data, logs, and other communication data and the resources that you access and use on or through the Services.
Device information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, and mobile network information.

The information we collect automatically is only statistical data and does not, in and of itself, include personal information, but we may maintain it or may associate it with other personal or business information we collect in other ways or receive from third parties. This information helps us to improve our Services and to deliver a better and more personalized service, including by enabling us to:

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Services according to your individual interests.
Speed up your searches.

The technologies we use for automatic information collection include cookies. A cookie is a small file placed on the hard drive of your computer. We use session-based cookies, which are cookies that last only while your browser is open and are automatically deleted when you close your browser. You may refuse to accept cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Services, and overall functionality of the Services may be impaired. For example, refusing to accept cookies may not allow you to stay signed into the Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Services.

We may use web analytics tools provided by service providers, including, but not limited to, Google Analytics, which is a third-party service that transmits website traffic data to Google services in the United States. These tools place session and persistent cookies in your browser to identify you as a unique user the next time you visit, access, or use the Services. Each cookie cannot be used by anyone other than the service provider (e.g., Google Analytics). We may use reports provided by Google Analytics and similar service providers to help us understand traffic on the Services and improve the Services. For more information concerning Google Analytics and how it collects and processes data, please see “How Google Uses Data When You Use Our Partners Web Sites or Apps,” located at https://policies.google.com/technologies/partner-sites. To prevent this data from being used by Google Analytics, follow the instructions to download and install the Google Analytics Opt-out Browser Add-on for each web browser you use.

C. From Third Parties

We may also receive personal information or draw inferences about you from other sources, including, without limitation, service providers who collect or process information on our behalf. We generally require these service providers to use your personal information only as we direct and in a manner consistent with this Policy.

6. How We Use Your Personal Information

We may use the personal information that we collect about you or that you provide to us:

To provide you with the Services, all related content, and any other information, products, or services that you request from us.
To create, manage, maintain, and secure your account and to provide you with notices about your account.
To communicate with you and to process your requests.
To give you notices about your account.
To notify you of changes or additions to any products or services we offer through the Services.
To notify you to participate in interactive features of the Services.
To help maintain the safety, security, and integrity of the Services, as well as our products, services, databases, and other technology assets.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
For testing, research, analysis, and product development, including to understand our audience, develop and improve the Services, as well as our customer service, products, and services.
To respond to law enforcement requests and, as required by applicable law, court order or governmental regulations.
To evaluate, negotiate, or conduct a merger, divestiture, restructuring, reorganization, dissolution, other sale or transfer of some or all of our assets, or the negotiation thereof, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users and customers is among the assets transferred.
To fulfill any other purpose for which you provide it.
For any other purpose with consent.

7. Disclosure of Your Information

We may disclose personal information that we collect or that you provide from any category identified above in Section 4 (Information We Collect):

To our subsidiaries and affiliates.
To our software and hosting provider, Magic EdTech. Its privacy policy can be viewed at https://www.magicedtech.com/privacy-policy.
To contractors, service providers, advisors, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
To an actual or perspective buyer or other successor in the event of an actual or proposed merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users is among the assets transferred.
To fulfill the purpose for which you provide it.
To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce our rights arising from any contracts entered into between you and us, and for billing and collection.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.
For any other purpose disclosed by us when you provide the information.
With your consent.

We may use or disclose aggregated information about our users and information that does not identify any individual without restriction. However, we do not sell your personal information, and we do not collect, use, or disclose your personal information for targeted advertising or marketing purposes.

8. Your Privacy Rights

We provide all users with rights to:

Confirm whether we process their personal information.
Access, correct, and delete certain personal information.
Data portability.
Opt-out of personal data processing for targeted advertising and sales.
Opt-out of certain types of profiling.

To exercise any of these rights, please contact us using the information set forth in Section 14 (How to Contact Us) below. We may deny a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect, and we may retain copies of your personal information to the extent required by applicable law.

To appeal a decision regarding a consumer rights request, please contact us as set forth in Section 14 (How to Contact Us).

9. Other Privacy Choices

We strive to provide you with as many choices as possible regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Account Access. You can review, change, and remove some of your personal information by logging into the Services and visiting your account profile page.

Tracking Technologies. You can set your browser to refuse all or some cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, some parts of the Services may then be inaccessible or not function properly.

Promotional Offers from Us. If you do not wish to have your contact information used by us to promote our own products or services, you can opt-out by unsubscribing from any emails you receive from us. Additionally, you can also always opt-out by contacting us as provided in Section 14 (How to Contact Us). We will not send promotional offers to any users.

Accessing and Updating Your Information. To update your information (such as name or email address), you can review and change some of your personal information by logging into the Services and visiting your account settings page. You may also contact us as provided in Section 14 (How to Contact Us) to update your information.

If you are a resident of certain jurisdictions (e.g., European Economic Area, California), you may have additional rights and choices regarding your personal information. Please see Section 15 (Notice for Individuals Located in the European Economic Area, Switzerland, and the United Kingdom) and Section 16 (Notice for California Residents) for additional information.

10. Security

We implement various physical, administrative, and technical safeguards in accordance with industry standards to protect the security of your personal information both online and offline. The safety and security of your information also depends on you. Where you have a password for access to certain parts of the Services, you are responsible for keeping this password confidential. Do not share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

11. Children’s Privacy

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 11 (Children’s Privacy), “parents”) about our practices for collecting, using, and disclosing personal information from children under the age of 13. It also requires us to obtain verifiable consent from a child’s parent or legal guardian for collection, use, and disclosure of the child’s personal information.

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

This Section 11 (Children’s Privacy) notifies parents of:

The types of personal information we may collect from children.
How we use the personal information we collect.
Our practices for disclosing that personal 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 personal information from children through the Services.

If we learn we have collected or received personal information directly from a child without parental consent or otherwise in violation of applicable law, we will delete that information, unless we have a legal obligation to keep it, and we will terminate the child’s account.

A. Personal Information We Collect from Children, How We Use the Information, and Our Practices for Disclosing

As a result of your child’s use of the Services, we may collect the following categories of personal information from your child:

Personal information, such as:
- Identifiers, including name, username and/or email address, age, and other similar identifiers.
- Education information, including grade, course information, and class lists.
- Location information, to the extent it can be derived from your child’s IP address.
- Inferences drawn from any of the above.
- Any other personal information that is uploaded or shared on the Services.
Information that is about your child but individually does not identify your child, such as information which has been de-identified or aggregated in a manner where it can no longer be used to identify your child.
Information about your child’s internet connection and the equipment your child uses to access the Services; IP address, approximate location, and other unique device identifiers; your child’s activity on the Services; and other usage details collected through your child’s use of the Services.

We may collect the personal information through any of the methods identified in Section 5 (How We Collect Personal Information). The personal information we collect from your child may be used for any of the purposes identified in Section 6 (How We Use Your Personal Information).

We do not sell any personal information, including any personal information collected from or about a child. We do not share or transfer children’s personal information other than as described in Section 7 (Disclosure of Your Personal Information), and we do not make children’s personal information publicly available in any fashion. However, we may disclose aggregated or de-identified information about any of our users, including children.

We may receive personal information from and disclose personal information to our software and hosting provider, Magic EdTech. Magic EdTech is contractually required to keep any information disclosed to it confidential and to not use or disclose any information provided to it.

B. 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, 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, or by contacting us by any of the methods listed in Section 14 (How to Contact Us).

C. Operators That Collect or Maintain Information from Children

No other third-party operators may collect or maintain personal information from children through the Site or Services.

12. Student’s Privacy

The Family Education Rights and Privacy Act (FERPA) governs the use of personal information contained in educational records, including any personal information directly related to a student user that is maintained by a School or a party acting for or on behalf of a School (“Educational Information“). Educational Information may include grades, transcripts, class lists, and student course schedules. Our collection and use of Educational Information is governed by this Section 12 (Student’s Privacy), our contracts with Schools, and all applicable privacy law.

In providing the Services, we collect Educational Information including course information, and class lists. We only redisclose Educational Information to our affiliates and service providers, and only for the purpose of providing the Services.

Pursuant to FERPA, we are acting as a school official with a legitimate educational interest and performing an institutional service or function for which the school would otherwise use employees, under the direct control of the school, with respect to the use and maintenance of Educational Information. We use Educational Information only for an authorized purpose and do not re-disclose it to third parties or affiliates, unless permitted under applicable law, without permission from the school or pursuant to court order.

In our effort to protect Educational Information, we comply with the following guidelines:

We collect, use, and redisclose Educational Information only for an authorized educational purpose in connection with the Services, or as directed by the School, the student user, or the student user’s parent or legal guardian.
We do not use Educational Information for targeted advertising or marketing purposes. We do not allow for third-party advertising, and we do not advertise to students, and therefore there is no behavioral or targeted advertising.
We maintain a security program designed to protect unauthorized access of Educational Information and take reasonable steps to protect Educational Information from unauthorized access, destruction, use, modification, or disclosure.
We seek to protect Educational Information stored within the Services through reasonable technical, physical, and administrative safeguards.
The Services are operated and managed on servers located and operated primarily in the United States.
We will not sell Educational Information unless the sale is part of a corporate transaction, such as a merger, acquisition, bankruptcy, or other sale of assets.
We will aggregate or de-identify Educational Information used for purposes of helping us to improve our services or develop or improve our products or services.
We will contractually require any service providers that we engage in connection with the Services who may receive Educational Information acquired through our Services to use the information only to provide the contracted services, not redisclose the information, to maintain reasonable data security measures, and to comply with applicable data privacy laws.
We will not knowingly retain Education Information beyond the time period required to support an educational purpose, unless authorized by the School.
We will delete Educational Information if the School requests deletion of data under its control. Ultimately, the School has direct control over our use and maintenance of any Educational Information.

If you have any questions about reviewing, modifying, or deleting the educational records of a student user accessing the Services through a School, please contact your School directly.

13. Changes to this Policy

We reserve the right to review and revise this Policy from time to time, without prior notice, subject to applicable legal requirements to provide you prior notice or obtain your consent. The date this Policy was last reviewed and/or revised is noted at the top of the page. You are responsible for periodically visiting the Services and this Policy to check for any changes. Your continued use of the Services following the posting of changes constitutes your acceptance of such changes.

14. How to Contact Us

To ask questions or comment about this Policy and our privacy practices, you may contact us:

Via mail at 4055 W Peterson Avenue, Suite 200, Chicago, IL 60646
Via phone at 1-844-553-8895
Via email at [email protected]

If you are a Data Subject and feel we have not resolved a privacy concern related to personal information processed or transferred by the Company, you have the right to submit a complaint to a supervisory authority.

15. Notice for Individuals Located in the European Economic Area, Switzerland, or the United Kingdom

A. Scope

This Section 15 applies exclusively to visitors and users of the Services who are located in the European Union (EU) and/or European Economic Area (EEA), Switzerland, or the United Kingdom (“Data Subjects“).

B. Rights of Data Subjects

We want to make sure you are fully aware of all of your data protection rights. If you are a Data Subject, you have the following rights:

Access. You have the right to request copies of your personal information. If you require more than one copy, we may charge you a reasonable fee.
Rectification. You have the right to request that we correct any personal information that you believe is inaccurate, or to complete any personal information which you believe is incomplete.
Erasure. You have the right to request that we erase your personal information, under certain circumstances.
Restrict Processing. You have the right to request that we restrict the processing of your personal information, under certain circumstances.
Object to Processing. You have the right to object to our processing of your personal information, under certain circumstances.
Data Portability. You have the right to request we transfer data that we have collected to you or directly to another organization, under certain circumstances.
Withdraw Consent. You have the right to withdraw your consent, explicit or otherwise, at any time. If we rely on your consent as the legal basis for our processing of your personal information, we will refrain from processing your data.

For the purposes of European data protection laws, we are the data controller, i.e., the company responsible for controlling the processing of personal information covered by this Policy.

If you are a Data Subject and would like to exercise any of these rights, please contact us as provided in Section 14 (How to Contact Us).

C. Transfer of Personal Information

The Services are operated and managed on servers located and operated primarily in the United States. Any information collected through the Services as described in this Policy is primarily stored in the United States. The United States is not recognized as having adequate safeguards by the European Economic Area, Switzerland, or the United Kingdom. If you are located outside of the United States, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer, storage, and further processing of information to the United States.

16. Notice for California Residents

A. Scope; Definitions

This Section 16 (Notice for California Residents) applies exclusively to visitors and users of the Services who reside in the state of California (“Consumers“). We provide this Notice to supplement our Klett World Languages Learning Platform Privacy Policy and to comply with California privacy laws, including the California Consumer Privacy Act of 2018 (the “CCPA“) as amended by the California Privacy Rights Act of 2020. Notwithstanding anything to the contrary elsewhere in this Policy, terms defined in the CCPA have the meaning assigned to them under the CCPA when used in this Notice.

If you are a Consumer, the CCPA provides you with certain rights regarding your personal information. This Section 16 (Notice for California Residents) includes additional notices with respect to and describes those rights and provides you with additional information regarding our practices regarding the collection, use, disclosure, and sale and sharing of personal information.

B. Personal Information We Collect

We may collect, and in the last 12 months have collected, the following categories of personal information from Consumers:

Category	Examples
A. Identifiers	A real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	A name, signature, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information.
D. Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
F. Professional or employment-related information	Current or past job history and information of the school or other institution where you work or study
G. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as course information, class lists, or student schedules.
H. Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Sensitive personal information is a subtype of personal information consisting of specific information categories. We do not collect sensitive personal information.

C. Sources of Personal Information

We may collect your personal information from the categories of sources of personal information identified in Section 5 (How We Collect Personal Information).

D. Use of Personal Information

We may use, disclose, or otherwise process the personal information we collect for the purposes identified in Section 6 (How We Use Your Personal Information) and Section 7 (Disclosure of Your Information).

E. Sharing Personal Information

We may share your personal information by disclosing it to a third party for a business purpose. We make these business purpose disclosures under written contracts that describe the appropriate business purpose, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding 12 months, we have disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.

We do not sell or share personal information, as those terms are defined by the CCPA.

Personal Information Category	Category of Third-Party Recipients
Personal Information Category	Business Purpose Disclosures	Sales or Sharing
A. Identifiers	Service providers (e.g., software and hosting vendors, etc.), Internet and cloud service providers	None
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Service providers (e.g., software and hosting vendors, etc.), Internet and cloud service providers	None
D. Internet or other similar network activity	Service providers (e.g., software and hosting vendors), Internet and cloud service providers, operating systems, and platforms	None
F. Professional or employment-related information	Service providers (e.g., software and hosting vendors), Internet and cloud service providers	None
G. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	Service providers (e.g., software and hosting vendors), Internet and cloud service providers	None
H. Inferences drawn from other personal information	None	None

F. Your Rights and Choices

The CCPA provides Consumers with certain rights regarding their personal information. This Section 16(F) describes these rights and explains how you may exercise them.

i) Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information (your “Right to Know“). Once we receive your request and confirm your identity, we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we shared that personal information.
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

You also have the right to request that we provide to you the specific pieces of personal information that we have collected in a readily useable format (also called a “Data Portability Request“).

ii) Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (your “Right to Delete“). Once we receive your request and confirm your identity (see Section 16(F)(iv) (Exercising Your Rights to Know or Delete)), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Additionally, if you are under 18 years old, you have the right to request that we remove any other content or information posted by you, to the extent the content or information is visible to any other user.

iii) Right to Correct

You have the right to request that we correct personal information that we maintain about you if you believe it is inaccurate (your “Right to Correct”). We may request documentation to validate your request and will use reasonable efforts to correct the personal information. In certain applications, you can also correct certain personal information we maintain about you by logging into your account and editing your profile or account information.

iv) Exercising Your Rights to Know, Delete, or Correct

To exercise your Right to Know or your Right to Delete described above, please submit a request by either:

Calling us at 844-553-8895;
Emailing us at [email protected]; or
Visiting us at klettlp.com

Only you or your authorized agent may make a verifiable consumer request related to your personal information. To designate an authorized agent, contact us through one of the methods listed above.

You may only make a Request to Know, Data Access Request, or Data Portability Request twice within a 12-month period. Your Request to Know, Data Access Request, or Data Portability Request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or are an authorized representative of such person, which may include:
- Information which we already maintain; or
- If we cannot verify your identity based on information already maintained by us, such information that we or our representatives request from you.

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

v) Response Timing and Format

We will confirm receipt of your request within 10 business days. If you do not receive confirmation within this timeframe, please contact us as provided above.

We try to substantively respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period. We cannot respond to your request or provide you with personal information unless we can verify your identity or authority to make the request and confirm the personal information relates to you. If we cannot verify your request within 45 days of its receipt, we may deny your request.

The response we provide will also explain the reasons we cannot comply with a request, if applicable. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

vi) Personal Information Sales and Sharing Opt-out and Opt-in Rights

If you are age 16 or older, you have the right to direct us to not sell or share your personal information at any time (the “right to opt-out”). We do not sell or share personal information and therefore do not sell or sharethe personal information of Consumers we actually know are less than 16 years old.

vii) Non-Discrimination; Notice of Financial Incentives

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

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior consent, which you may revoke at any time. We do not currently provide financial incentives.

17. Notice for Nevada Residents

This Section 17 applies exclusively to visitors and users of the Services who reside in the state of Nevada. Nevada provides its residents with a limited right to opt-out of certain personal information sales. Nevada residents who wish to exercise this sale opt-out right may email us at [email protected]. Please include “Nevada” in your email subject line and include the following information in your email: (i) your name, (ii) Nevada resident address, and (iii) email address. However, please know we do not currently sell data triggering that statute’s opt-out requirements.