1. What Data We Get
1.1 Data You Provide to Us
We may collect different data from or about you depending on how you use the Services. Below are some examples to help you better understand the data we collect.
When you create an account and use the Services, including through a third-party platform, we collect any data you provide directly, including:
|Account Data||In order to use certain features (like accessing content), you need to create a user account. When you create or update your account, we collect and store the data you provide, like your email address, password, phone number, occupation, skill interests, gender, race, ethnicity, government ID information, verification photo, age, date of birth, and account settings and assign you a unique identifying number (“Account Data”).|
|Profile Data||You can also choose to provide profile information like a photo, headline, biography, language, website link, social media profiles, country, or other data. Your Profile Data will be publicly viewable by others.|
|Shared Content||Parts of the Services let you interact with other users or share content publicly, including by posting reviews about content, asking or answering questions, sending messages to students or vendors, or posting photos or other work you upload. Such shared content may be publicly viewable by others depending on where it is posted.|
|Educational Content Data||When you access content, we collect certain data including which courses, assignments, labs, workspaces, and quizzes you’ve started and completed; content purchases and credits; subscriptions; completion certificates; your exchanges with vendors, and other students; and essays, answers to questions, and other items submitted to satisfy course and related content requirements. If you are an vendor, we store your educational content which may contain data about you.|
|Student Payment Data||If you make purchases, we collect certain data about your purchase (such as your name and ZIP code) as necessary to process your order. You must provide certain payment and billing data directly to our payment service providers, including your name, credit card information, billing address, and ZIP code. We may also receive limited information, like the fact that you have a new card and the last four digits of that card, from payment service providers to facilitate payments. For security, Vogate does not collect or store sensitive cardholder data, such as full credit card numbers or card authentication data.|
|Data About Your Accounts on Other Services||We may obtain certain information through your social media or other online accounts if they are connected to your Vogate account. If you login to Vogate via Facebook or another third-party platform or service, we ask for your permission to access certain information about that other account. For example, depending on the platform or service we may collect your name, profile picture, account ID number, login email address, location, physical location of your access devices, gender, birthday, and list of friends or contacts.
Those platforms and services make information available to us through their APIs. The information we receive depends on what information you (via your privacy settings) or the platform or service decide to give us.
If you access or use our Services through a third-party platform or service, or click on any third-party links, the collection, use, and sharing of your data will also be subject to the privacy policies and other agreements of that third party.
The data listed above is stored by us and associated with your account.
1.2 Data We Collect through Automated Means
When you access the Services (including browsing content), we collect certain data by automated means, including:
|System Data||Technical data about your computer or device, like your IP address, device type, operating system type and version, unique device identifiers, browser, browser language, domain and other systems data, and platform types (“System Data”).|
|Usage Data||Usage statistics about your interactions with the Services, including content accessed, time spent on pages or the Service, pages visited, features used, your search queries, click data, date and time, referrer, and other data regarding your use of the Services (“Usage Data”).|
|Approximate Geographic Data||An approximate geographic location, including information like country, city, and geographic coordinates, calculated based on your IP address.|
The data listed above is collected through the use of server log files and tracking technologies, as detailed in the “Cookies and Data Collection Tools” section below. It is stored by us and associated with your account.
1.3 Data From Third Parties
If you are a Vogate for Business enterprise or corporate prospect, we may collect certain business contact information from third-party commercial sources.
2. How We Get Data About You
2.1 Cookies and Data Collection Tools
2.2 Why We Use Data Collection Tools
Vogate uses the following types of Data Collection Tools for the purposes described:
- Strictly Necessary: These Data Collection Tools enable you to access the site, provide basic functionality (like logging in or accessing content), secure the site, protect against fraudulent logins, and detect and prevent abuse or unauthorized use of your account. These are required for the Services to work properly, so if you disable them, parts of the site will break or be unavailable.
- Functional: These Data Collection Tools remember data about your browser and your preferences, provide additional site functionality, customize content to be more relevant to you, and remember settings affecting the appearance and behavior of the Services (like your preferred language or volume level for video playback).
- Performance: These Data Collection Tools help measure and improve the Services by providing usage and performance data, visit counts, traffic sources, or where an application was downloaded from. These tools can help us test different versions of Vogate to see which features or content users prefer and determine which email messages are opened.
- Advertising: These Data Collection Tools are used to deliver relevant ads (on the site and/or other sites) based on things we know about you like your Usage and System Data (as detailed in Section 1), and things that the ad service providers know about you based on their tracking data. The ads can be based on your recent activity or activity over time and across other sites and services. To help deliver tailored advertising, we may provide these service providers with a hashed, anonymized version of your email address (in a non-human-readable form) and content that you share publicly on the Services.
- Social Media: These Data Collection Tools enable social media functionality, like sharing content with friends and networks. These cookies may track a user or device across other sites and build a profile of user interests for targeted advertising purposes.
3. What We Use Your Data For
We use the data we collect through your use of the Services to:
- Provide and administer the Services, including to facilitate participation in educational content, issue completion certificates, display customized content, and facilitate communication with other users;
- Process payments to vendors and other third parties;
- Process your requests and orders for educational content, products, specific services, information, or features;
- Communicate with you about your account by:
- Responding to your questions and concerns;
- Sending you administrative messages and information, including messages from vendors, students; notifications about changes to our Service; and updates to our agreements;
- Sending you information, such as by email or text messages, about your progress in courses and related content, rewards programs, new services, new features, promotions, newsletters, and other available vendor-created content (which you can opt out of at any time);
- Sending push notifications to your wireless device to provide updates and other relevant messages (which you can manage from the “options” or “settings” page of the mobile app);
- Manage your account and account preferences;
- Facilitate the Services’ technical functioning, including troubleshooting and resolving issues, securing the Services, and preventing fraud and abuse;
- Solicit feedback from users;
- Market products, services, surveys, and promotions;
- Market Subscription Plans to prospective customers;
- Learn more about you by linking your data with additional data through third-party data providers and/or analyzing the data with the help of analytics service providers;
- Identify unique users across devices;
- Tailor advertisements across devices;
- Improve our Services and develop new products, services, and features;
- Analyze trends and traffic, track purchases, and track usage data;
- Advertise the Services on third-party websites and applications;
- As required or permitted by law; or
- As we, in our sole discretion, otherwise determine to be necessary to ensure the safety or integrity of our users, employees, third parties, the public, or our Services.
4. Who We Share Your Data With
- With Your Vendors: We share data that we have about you (except your email address) with vendors for educational content you access or request information about, so they can improve their content for you and other students. This data may include things like your city, country, browser language, operating system, device settings, the site that brought you to Vogate, and your activities on Vogate. If we collect additional data about you (like age or gender), we may share that too. We will not share your email address with vendors .
- With Other Students and Vendors: Depending on your settings, your shared content and profile data may be publicly viewable, including to other students and vendors. If you ask a question to an vendor, your information (including your name) may also be publicly viewable.
- With Service Providers, Contractors, and Agents: We share your data with third-party companies who perform services on our behalf, like payment processing, fraud and abuse prevention, data analysis, marketing and advertising services (including retargeted advertising), email and hosting services, and customer services and support. These service providers may access your personal data and are required to use it solely as we direct, to provide our requested service.
- With Vogate Affiliates: We may share your data within our corporate family of companies that are related by common ownership or control to enable or support us in providing the Services.
- With Business Partners: We have agreements with other websites and platforms to distribute our Services and drive traffic to Vogate. For example, we work with Benesse in Japan. Depending on your location, we may share your data with these partners.
- With Analytics and Data Enrichment Services: As part of our use of third-party analytics tools like Google Analytics and data enrichment services like ZoomInfo, we share certain contact information, Account Data, System Data, Usage Data (as detailed in Section 1), or de-identified data as needed. De-identified data means data where we’ve removed things like your name and email address and replaced it with a token ID. This allows these providers to provide analytics services or match your data with publicly-available database information (including contact and social information from other sources). We do this to communicate with you in a more effective and customized manner.
- To Administer Promotions and Surveys: We may share your data as necessary to administer, market, or sponsor promotions and surveys you choose to participate in, as required by applicable law (like to provide a winners list or make required filings), or in accordance with the rules of the promotion or survey.
- For Advertising: If we decide to use an advertising-supported revenue model in the future, we may use and share certain System Data and Usage Data with third-party advertisers and networks to show general demographic and preference information among our users. We may also allow advertisers to collect System Data through Data Collection Tools (as detailed in Section 2.1), to use this data to offer you targeted ad delivery to personalize your user experience (through behavioral advertising), and to undertake web analytics. Advertisers may also share with us the data they collect about you. To learn more or opt out from participating ad networks’ behavioral advertising, see Section 6.1 (Your Choices About the Use of Your Data) below. Note that if you opt out, you’ll continue to be served generic ads.
- For Security and Legal Compliance: We may disclose your data to third parties if we (in our sole discretion) have a good faith belief that the disclosure is:
- Permitted or required by law;
- Requested as part of a judicial, governmental, or legal inquiry, order, or proceeding;
- Reasonably necessary as part of a valid subpoena, warrant, or other legally-valid request;
- Required to detect, prevent, or address fraud, abuse, misuse, potential violations of law (or rule or regulation), or security or technical issues; or
- Reasonably necessary in our discretion to protect against imminent harm to the rights, property, or safety of Vogate, our users, employees, members of the public, or our Services.
- During a Change in Control: If Vogate undergoes a business transaction like a merger, acquisition, corporate divestiture, or dissolution (including bankruptcy), or a sale of all or some of its assets, we may share, disclose, or transfer all of your data to the successor organization during such transition or in contemplation of a transition (including during due diligence).
- After Aggregation/De-identification: We may disclose or use aggregated or de-identified data for any purpose.
Vogate takes appropriate security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal data that we collect and store. These measures vary based on the type and sensitivity of the data. Unfortunately, however, no system can be 100% secured, so we cannot guarantee that communications between you and Vogate, the Services, or any information provided to us in connection with the data we collect through the Services will be free from unauthorized access by third parties. Your password is an important part of our security system, and it is your responsibility to protect it. You should not share your password with any third party, and if you believe your password or account has been compromised, you should change it immediately and contact our Support Team with any concerns.
6. Your Rights
6.1 Your Choices About the Use of Your Data
You can choose not to provide certain data to us, but you may not be able to use certain features of the Services.
- To stop receiving promotional communications from us, you can opt out by using the unsubscribe mechanism in the promotional communication you receive or by changing the email preferences in your account. Note that regardless of your email preference settings, we will send you transactional and relationship messages regarding the Services, including administrative confirmations, order confirmations, important updates about the Services, and notices about our policies.
- If you’re located in the European Economic Area, you may opt out of certain Data Collection Tools by clicking the “Cookie settings“ link at the bottom of any page.
- The browser or device you use may allow you to control cookies and other types of local data storage. To learn more about managing cookies, visit https://cookiepedia.co.uk/how-to-manage-cookies. Your wireless device may also allow you to control whether location or other data is collected and shared.
- To opt out of allowing Google Analytics, Mixpanel, ZoomInfo, or Clearbit to use your data for analytics or enrichment, see the Google Analytics Opt-out Browser Add-on, Mixpanel Opt-Out Cookie, ZoomInfo’s policy, and Clearbit data claiming mechanism.
- Apple iOS, Android OS, and Microsoft Windows each provide their own instructions on how to control in-app tailored advertising. For other devices and operating systems, you should review your privacy settings on that platform.
If you have any questions about your data, our use of it, or your rights, contact us at [email protected].
6.2 Accessing, Updating, and Deleting Your Personal Data
You can access and update your personal data that Vogate collects and maintains as follows:
- To update data you provide directly, log into your account and update your account at any time.
- To terminate your account:
- If you are a student, visit your profile settings page and follow the steps detailed.
- If you are an vendor, follow the steps detailed.
- If you have any issues terminating your account, please contact our Support Team.
- To request to access, correct, or delete your personal data, please use our online form here. You can also submit these requests by emailing [email protected] or writing to us at Atom Services T/A Vogate, Attn: Legal, Imperial Offices, 2 Heigham Road, East Ham. London. E6 2JG. Please allow up to 30 days for a response. For your protection, we may require that the request be sent through the email address associated with your account, and we may need to verify your identity before implementing your request. Please note that we retain certain data where we have a lawful basis to do so, including for mandatory record-keeping and to complete transactions.
6.3 Our Policy Concerning Children
We recognize the privacy interests of children and encourage parents and guardians to take an active role in their children’s online activities and interests. Individuals younger than 18 years of age, but of the required age for consent to use online services where they live (for example, 13 in the US or 16 in Ireland), may not set up an account, but may have a parent or guardian open an account and help them access appropriate content. Individuals younger than the required age for consent to use online services may not use the Services. If we learn that we’ve collected personal data from a child under those ages, we will take reasonable steps to delete it.
Parents who believe that Vogate may have collected personal data from a child under those ages can submit a request that it be removed to [email protected].
7. Jurisdiction-Specific Rules
7.1 Users in California
Users who are California residents have certain rights under the California Consumer Privacy Act, (“CCPA”). If you are an eligible California user, included in these rights are:
- “Right to Know” — You have the right to request to know more about the categories and specific pieces of personal information that we have collected about you and access a copy of your personal information.
- “Right to Deletion” — You have the right to request deletion of personal information that we have collected about you.
- “Right to Non-Discrimination” — If you choose to exercise any of your rights under CCPA, Vogate will treat you like all other users. In other words, there is no penalty for exercising your rights under CCPA.
- “Right to Opt-Out” – You have the right to opt out of the sale of your personal information.
To exercise any of these rights under CCPA, please email [email protected] or write to us at Atom Services T/A Vogate, Attn: Legal, Imperial Offices, 2 Heigham Road, East Ham. London. E6 2JG. CCPA allows you to designate an authorized agent to make these requests on your behalf. For your protection, we may require that the request be sent through the email address associated with your account, and we may need to verify you and/or your agent’s identity before fulfilling your request.
Additionally, for more information about the personal information we collect and how we collect it, please see the sections above entitled “What Data We Get” and “How We Get Data About You.”
To learn about the business and commercial purposes for which your personal information is collected and the categories of service providers who have access to your personal information, please see the sections above entitled “What We Use Your Data For” and “Who We Share Your Data With.”
As a California resident, you also have the right to request certain details about what personal information we share with third parties for those third parties’ direct marketing purposes. To submit your request, send an email to [email protected] with the phrase “California Shine the Light” and include your mailing address, state of residence, and email address.
Since there is no widely accepted standard for the browser-initiated Do Not Track signal, we do not currently recognize or respond to Do Not Track signals.
7.2 Users in Nevada
Vogate does not sell its users’ personal information or personal data. Nonetheless, Nevada residents have the right to submit a request that we do not sell your covered personal information, which you can do by emailing [email protected] or writing to us at Atom Services T/A Vogate, Attn: Legal, Imperial Offices, 2 Heigham Road, East Ham. London. E6 2JG.
7.3 Users in Australia
If you are an Australia resident and you have a complaint, you may refer it to the office of the Australian Information Commissioner (“OAIC”). You can contact OAIC by visiting www.oaic.gov.au; forwarding an email to [email protected]; telephoning 1300 363 992; or writing to OAIC at GPO Box 5218, Sydney NSW 2001.
7.4 Users Outside of the U.S.
In order to provide the Services to you, we must transfer your data to the United States and process it there. By visiting or using our Services, you consent to storage of your data on servers located in the United States. If you are using the Services from outside the United States, you consent to the transfer, storage, and processing of your data in and to the United States or other countries. Specifically, personal data collected in the United Kingdom (“UK”), Switzerland, and the European Economic Area (“EEA”) is transferred and stored outside those areas. Additionally, if you are located in the EEA, UK, or Switzerland, you also have the right to lodge a complaint with your data supervisory authority.
Personal data is also processed outside of the UK, Switzerland, and the EEA by our Vogate group companies, or our service providers, including to process transactions, facilitate payments, and provide support services as described in Section 4. We use Standard Contractual Clauses adopted by the European Commission to facilitate transfers of personal data from the EEA to third countries and have entered into data processing agreements with our service providers and Atom Services Limited to restrict and regulate their processing of your data. By submitting your data or using our Services, you consent to this transfer, storage, and processing by Vogate and its processors.
8. Updates & Contact Info