@h4 Introduction Welcome! You have arrived at a website or mobile application operated by Coughlan Companies, LLC or Capstone Global Ltd. (collectively, [b]“Capstone,” “we”, “our”[/b] or [b]“us”[/b]). Capstone is the nation’s leading educational publisher for digital solutions, children’s books, and literacy programs for school libraries and classrooms! Home of award-winning content platforms and easy-to-use creation tools, Capstone has a passion for creating inspired learning and intellectual curiosity in children. At Capstone, we take your privacy and the privacy of your students very seriously. This Privacy Notice ([b]“Notice”[/b]) describes the types of personal information (as defined below) that we collect in our Products (defined below), how we use it, how and when we share it, and the rights you have with respect to your information. It also explains how we communicate with you and how you can make inquiries and requests to us about your information. We strive to help you understand how we use your information to improve our products, services, marketing, and interactions with you, as part of our commitment to maintaining your trust. @h4 Scope This Notice applies when you use the products PebbleGo (Including Add-Ons), Capstone Interactive, Capstone Connect Educator Tools, PebbleGo Create, Raintree (Including Raintree Online and Engage Literacy), and other Capstone products and mobile applications (collectively, the “[b]Products[/b]”), or otherwise provide Personal Information or interact with us online or in-person in connection with your use of such Products. We also support our Products by providing various “[b]Services[/b]” such as customer support. By using our Products and Services, you agree to this Notice and our [b]Product End User License Agreement[/b]. For the purpose of this Notice, "[b]Personal Information[/b]" means any personal information relating to an identified or identifiable individual. For the Privacy Notice for the Capstone Publishing, Capstone online store, or Raintree online store websites, please visit [url=/support/privacy/corporate-privacy-notice]here[/url]. If you have any questions about this Privacy Notice, please contact us at [url=mailto:privacy@capstonepub.com]privacy@capstonepub.com[/url]. @h4 Children’s Privacy Policy On select Products, Capstone collects a limited amount of Personal Information from children that is necessary for the Products to work. For more information about our practices regarding children’s Personal Information, please read our [url=/support/privacy/childrens-privacy-policy]Children’s Privacy Policy[/url]. @h4 What Information We Collect In connection with your use of our Products or Services, we may collect information, including Personal Information, from you where you expressly provide us with the information and as you use and navigate through our Products and Services. On occasion, we may obtain personal information about you from third parties. Examples of sources from which we collect information include information provided in our Products, via online chat or support services, web forms or inputs/uploads into our Products, telephone calls with you, letters, e-mails or other communications from you, documents you have provided to us, or references and referrals provided to us in connection with your electing to list as a service provider with us. This section describes the information we collect about you in connection with our Products and Services. @h5 Personal Information That We Collect About You In connection with your use of our Products or Services, we may collect Personal Information when you provide it to us directly, as well as when you use and navigate through our Products and Services. On occasion, we may obtain personal information about you from third parties. Examples of sources from which we collect information include information provided in our Products, via online chat or support services, web forms or inputs/uploads into our Products, telephone calls with you, letters, e-mails or other communications from you, documents you have provided to us, or references and referrals provided to us in connection with your electing to list as a service provider. This section describes the information we collect about you in connection with our Products and Services. @h5 Information That You Provide to Us We collect the following categories of Personal Information when you provided them through our Products and Services. @h6 PebbleGo Create * [b]Account and contact information.[/b] When you register an account to become a user of PebbleGo Create, we collect contact information such as your name, email, username and password. Educator and student accounts are created by syncing the School/District’s roster data with those integrations made available via Capstone’s Products. * [b]Financial information.[/b] We collect information relating to your purchase, including your credit card or debit card number, bank account information and your payment, service and purchase history. * Marketing information[/b]. If you sign up to receive marketing communications from us or interact with our products and/or services, we collect the details regarding informational and promotional materials you may have requested or received from us, the services in which you are interested, your receipt of promotional communications, and information on your marketing or communication preferences. * [b]Classroom, school or district information.[/b] We collect information such as building address, district name, and administrative contact email address(es) and phone number(s). * [b]Communications information.[/b] We collect copies of, and details regarding, communications and inquiries you have made to us, including when you communicate with us via telephone, email, through online chat or support services, web forms, or other inputs/uploads to our site. @h6 PebbleGo (Including Add-Ons), Capstone Interactive, Capstone Connect Educator Tools, and Raintree (Including Raintree Online and Engage Literacy) * [b]Account and contact information.[/b] When you register an account to become a user of Capstone's Products and Services, we collect contact information such as your first and last name, email address, home or business address, shipping address, telephone numbers, mobile numbers. From time to time, educator and student accounts are created by syncing the School/District’s roster data with those integrations made available via Capstone’s Products. * [b]Financial information.[/b] We collect information such as your credit card or debit card number, bank account information and your payment, service and purchase history. * [b]Marketing information.[/b] If you sign up to receive marketing communications from us or interact with our products and/or services, we collect the details regarding informational and promotional materials you may have requested or received from us, the services in which you are interested, your receipt of promotional communications, and information on your marketing or communication preferences. * [b]Classroom, school or district information.[/b] We collect information such as building address, district name, and administrative contact email address(es) and phone number(s). * [b]Communications information.[/b] We collect copies of, and details regarding, communications and inquiries you have made to us, including when you communicate with us via telephone, email, through online chat or support services, web forms, or other inputs/uploads to our site. Where permitted by the law and/or with your consent, in some circumstances, we may record or transcribe your communications with us using third-party technologies and may share those communications with third parties that supply the technology necessary to make the recordings or transcriptions. * [b]Query information.[/b] We have developed an AI-driven question-and-answer knowledge base called “Ask PebbleGo,” which uses a large language model to search our publications for items that may be responsive to certain types of requests. This search capability runs independently and without human interaction. It collects and retains search queries for the purpose of identifying materials that are responsive to the request but does not associate the query with a specific user. Your decision to provide us with Personal Information is voluntary, but if you choose not to provide any requested information, you may not be able to take advantage of all the features of the Products or Services. @h5 User Content PebbleGo Create allows users to submit, transmit, share, create, or post information. Such information may include personal information, such as photographs, video or audio files, or recordings of an individual’s voice. While this information may be submitted by a user to the Product, Capstone does not specifically collect this information about any user. Further, Capstone does not decide or control how any user-submitted information is used, published, or shared by users. @h5 Information That Is Automatically Collected Like many businesses, we and/or our service providers may automatically collect and/or store certain information when you use our Products and Services (“Usage Information”). This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you use our Products or Services. Usage Information may include: * Your IP address, device identifier, or another unique identifier; * Your Device functionality (including browser, browser language, settings and behavior, operating system, hardware, mobile network information); * Referring and exit web pages and URLs; * The areas within the Products that you visit and your activities there, including remembering you and your preferences; * Your Device characteristics; * Certain other Device data, including the time of day you use our Products or other information used to provide analytics or other usage information; * Information about your engagement with our emails; and * Statistical information about how both unregistered and registered users, collectively, use the Products and Services. This aggregate information is derived from Personal Information but cannot be tied back to you or your web browser. Please note that we endeavor to limit our automatic collection of data to those items that are necessary for the functionality of our Products. If you no longer wish for us or our service providers to collect and use the information described above, you may be able to disable certain features on your Device. Consult your Device manufacturer settings for instructions. Please note that if you disable such features, your ability to access certain features on our Products and Services may be limited or disabled. @h5 Information Collected Through Social Media If you interact with Capstone or our other users regarding Capstone and its Products on any social media platform: (a) depending on your social media privacy settings, the personal information that you submit on the social media platform may be read, collected, or used by us as described in this Policy, and (b) where Capstone responds to any interaction with you on social media, your account name/handle may be viewable by any and all members or users of our social media accounts. Social media platforms operate independently from Capstone, and we are not responsible for the personal information that you choose to submit on any social media platform. We encourage you to review the privacy policies and settings of any social media platform with which you interact to help you understand their privacy practices. @h5 Information Collected from Third Parties The Products may include functionality that permits certain kinds of interactions between the Products and your account on a third-party website or application, which may result in the third-party site providing information about you to us. For example, we might obtain information about the traffic and usage of our Products from third parties, or we may use third parties to facilitate emails or postings to social media (like a “Share” or “Forward” button). These third parties use cookies and other tracking technologies to capture information about your interactions with our products. Our products do not have control over the information that is collected, used, and shared by these third parties. We encourage you to review the privacy statements of these third parties to understand their privacy practices. We may also obtain information about you from our authorized sales representatives and resellers, business partners, contractors, suppliers, lead providers (such as MDR Education), and other third parties and add it to your account information or other information we have collected. We, and the third parties we engage, may combine information we collect from you over time, and across the Sites, with information obtained from other sources. This helps us improve the information’s overall accuracy and completeness, and also helps us better tailor our interactions with you. We may use third-party platforms and advertising services (e.g. Amazon, Google Merchant Center, TikTok Shop), to list and promote our products on external websites, marketplaces, search results, and shopping features. These providers may also help us measure the performance of our product listings, advertisements, and sales campaigns. In connection with these activities, limited information (such as product data, transaction details, or website interaction data) may be shared with these third parties in accordance with their policies and applicable law. @h4 How We Use Your Information We (and service providers acting on our behalf) use your information for the following purposes: @h6 To Verify Your Age We may ask you to verify your age prior to entering the PebbleGo Create Product. @h6 To Provide Our Services When you use our Products or Services, we use your personal information to: * provide educational services and content; * register and verify user accounts; *support and improve our Capstone Rewards loyalty program (for more information about the Capstone Rewards program, please see Notice of Financial Incentives section below or visit here; * facilitate the functionality of our Products, including any payments made via your Raintree account; * process your purchases of, distribution of, or requests for, Products and Services; * customize experiences and personalization when you are using our Products; *deliver services you have requested, which include the interaction, communication, creation and sharing within the classroom/school/district account. The data is necessary to provide the administrator-educator-student hierarchy within the account; * allow subscribers to create and manage classes, personalize and differentiate instruction, and monitor and assess student progress; * allow subscribers to monitor and safeguard student welfare; and * allow subscribers to set creation and sharing permissions and privacies schoolwide. @h6 To Communicate with You We process personal information in order to communicate with you in relation to your accounts, our services, our marketing, and your requests to: * inform subscribers about feature updates, site maintenance, and programs/initiatives (does not include subaccounts); * communicate with you about orders, purchases, returns, Services, accounts, programs, contests, and sweepstakes; * respond to your customer service inquiries and requests for information; * post your comments or statements on our websites; * send you promotions, content, special offers, and other marketing communications; * communicate with you about our brands, Products, events, or other promotional purposes; * implement your communications preferences, such as sharing information with our business partners so that they may email you about their promotions, products and initiatives; * provide important Product safety information and notice of product recalls; and * notify you about changes to our website, Services, products, or material changes to this Policy. @h6 For Research, Development, and Improvement of Our Products and Services We want to ensure that our Products and Services are continually improving and expanding so that we meet and exceed your needs and expectations. To do so, we may process certain personal information to: * maintain, improve, and analyze the Products we offer; and * detect, prevent, or investigate suspicious activity or fraud. @h6 To Enforce our Terms, Agreements, or Policies To maintain a safe, secure, and trusted environment for you when you use our Products and Services, we use your personal information to ensure our terms, policies, and agreements with you and any third parties are enforced. @h6 To Comply with Applicable Laws We may be required to process certain personal information under certain laws and regulations, such as tax laws, as well as to: * maintain appropriate records for internal administrative purposes; and * comply with applicable legal and regulatory obligations, and respond to lawful subpoenas or governmental requests, as needed. @h6 With Your Consent We may process certain personal information to fulfill any other business or commercial purposes described to you at the time we collect personal information from you, at your direction, or with your consent. @h4 Use of Cookies In connection with our Products, we use cookies, pixels, GIFs, web beacons, and similar technologies (collectively, “cookies”) that are essential for you to use the Products. For example, these cookies permit you to securely access the Products. These cookies are known as “strictly necessary” cookies and are usually only set in response to specific actions you take on the Products. Some cookies are called “first-party cookies,” meaning they come from us or service providers acting at our direction and for our benefit. Other cookies are called “third-party cookies,” meaning they are supplied by third-party vendors, if those vendors supply functionality that is essential to the operation of the Products. These third-party vendors may have access to the information collected through their cookies. These cookies will not be used to contact you. Other data technologies may be used that collect similar information for security and fraud detection purposes. @h4 Third Parties to Whom We Disclose Your Information @h5 Services Providers We share your Personal Information with our third-party service providers who provide services that are necessary for our Products and Services, such as website hosting, payment processing, online chat functionality, data analysis, information technology, fulfillment, customer service, email delivery, auditing and other services. A List of Service Providers and Subprocessors can be found [url=/content/dam/capstonepub/support/ThirdPartySubprocessorsCustomersCapstone2026.pdf]here[/url]. @h5 Marketing and Advertising Partners We share information about your use of our Products and Services, your purchases, and your interaction with our ads on other websites with our marketing and advertising partners that may assist with lead generation, hosting information relating to clients and potential clients, marketing automation, marketing campaigns, or providing you with targeted advertisements or marketing communications. We collect and share some of this information directly with our advertising partners, and in some cases using cookies or other similar technologies (which you may consent to, depending on your location). @h5 Authorized Representatives We use a network of independent sales representatives and resellers for marketing and sales purposes (“Representative”). We may share your information with these Representatives for the purposes of marketing our products and services, engaging in sales, and otherwise communicating information about our products and services to customers or potential customers. @h5 Other Aside from the instances described above, we will only share your personal information: * to comply with the law; * to respond to claims or comply with legal process served on Capstone (e.g., a lawful subpoena, warrant, or court order); * to enforce or apply our policies or agreements; * to protect and defend our rights or property or that of our customers, employees, visitors, or the public; * in connection with an acquisition, liquidation, divestiture, restructuring, reorganization, dissolution, or merger, or sale or transfer of some or all of our assets (including the negotiation of the same), whether as a going concern or as a part of bankruptcy, liquidation, or a similar proceeding, where the information is among the items being transferred; * if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure; and * to any other parties for any purpose we disclose to you at the time you provide the information or to which you otherwise consent. @h4 Third Party Links The Products may contain links to other websites such as social media platforms, other websites and partner websites. These websites are not covered by this Privacy Notice. Please review the Privacy Notices or Policies of those websites to understand the privacy practices of these third parties. We cannot and do not take responsibility for the content of any linked websites or those companies’ data-handling practices. @h4 Your Choices About the Collection and Use of Personal Information We strive to provide you with choices regarding your personal information. Some choices you have regarding the collection and use of your personal information include the following: * [b]Marketing Emails[/b]: If we ever send you promotional emails, you can stop receiving those emails by clicking the “unsubscribe” link in the email. We endeavor to promptly process any unsubscribe requests. * [b]Communication Preferences[/b]: You may change previously expressed preferences regarding how we use your information to communicate with you by accessing your “Account Settings” on our Sites or mobile apps. You can also contact us at [url=mailto:privacy@capstonepub.com]privacy@capstonepub.com[/url]. * [b]Do Not Track Signals[/b]: Capstone does monitor or take any action with respect to “Do Not Track” signals. * [b]Cookies[/b]: Depending on your browser or device, you may have the option to set the browser to accept all cookies, reject all cookies, notify you when a cookie is set, or delete cookies. Each browser and device are different, so we recommend you evaluate the tools and settings available in your browser or device, as well as any available instructions for the same. Please note that if you disable or delete cookies, you may not be able to access or use certain features of the Services. * Analytics: As discussed above, we use Google Analytics and other analytics services, such as Kibana, in connection with the Services. You can opt-out of Google Analytics here: [url=https://tools.google.com/dlpage/gaoptout]https://tools.google.com/dlpage/gaoptout[/url]. You can read more about how Google uses your Personal Information here: [url=https://policies.google.com/privacy?hl=en]https://policies.google.com/privacy?hl=en[/url]. * [b]Personalized or Interest-Based Advertising[/b]: To opt-out of personalized or interest-based advertisements, you may be able to adjust the settings on your device. Please go to your device settings and opt-out through the controls provided through Google/Android or iOS, as applicable. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at [url=https://www.networkadvertising.org/understanding-online-advertising/how-does-it-work]https://www.networkadvertising.org/understanding-online-advertising/how-does-it-work[/url]. You can opt out of targeted advertising by visiting the following: * Facebook - https://www.facebook.com/settings/?tab=ads * Google - https://adssettings.google.com * Bing - https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads * [b]Jurisdiction-specific choices[/b]: Depending on the jurisdiction where you reside, you may have additional choices or rights with respect to your personal information, as explained below. To protect your privacy and security, we may also take reasonable steps to verify your identity before making any changes. Finally, you can also choose not to provide us with information we may request through the Services, but that may result in you being unable to use certain features of our Services. @h4 Security We seek to use reasonable organizational, technical and administrative measures to protect Personal Information. Such measures may include, without limitation, taking reasonable steps to ensure the reliability of employees or service providers having access to your data; limited access rights and access controls; security and privacy training for employees; appropriate data backup, recovery, and incident management procedures; encryption in transit and at rest; secure hosting environments; background checks for applicable personnel; regular security monitoring and vulnerability assessments; and software protection of Devices on which personal data are stored. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. Where we have given you (or where you have chosen) a password so that you can access certain areas of our site, you are responsible for keeping this password confidential. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us at [url=mailto:privacy@capstonepub.com]privacy@capstonepub.com[/url] or [url=mailto:privacy@pebblego.com]privacy@pebblego.com[/url]. @h4 International Transfers of Personal Information For customers located outside of the United States, Capstone is headquartered in the United States and the Products are operated from the United States. If you are located in another jurisdiction, please know that your information will be transferred to, stored, and processed in the United States. By using the Products and providing us with information, you consent to the transfer, processing and storage of your information in the United States. It is important to note that the privacy laws in the United States may not be as comprehensive as those in other countries, such as countries in the European Union (“EU”). When we transfer your personal information from other countries, we will use appropriate safeguards to protect such transfers as may be required by applicable data protection laws. Specifically, if we transfer personal information from the EU, UK, or Switzerland to the United States or any other country, we will implement appropriate legal mechanisms to ensure an adequate level of personal data protection consistent with the GDPR’s requirements. For example, if the recipient country has not received an Adequacy Decision from the EU (such as the United States), we will rely on European Commission’s Standard Contractual Clauses (SCCs) as the lawful mechanisms for such transfers. Further, we will enter into appropriate data processing agreements with all non-EU (sub)processors which contain SCCs and define security standards to be employed by each (sub)processors. @h4 Your Rights Under the General Data Protection Regulation This section of our Privacy Notice applies if you are an individual in the European Economic Area (“EEA”), UK, or Switzerland. We adopted this Policy to comply the General Data Protection Regulation (“GDPR”), as adopted and applied in the EEA, UK, and Switzerland. Any terms defined in the GDPR have the same meaning when used in this Section. Capstone is the data controller for processing Personal Information provided to us through the Products and Services. We hope to ensure that the Personal Information we possess are always accurate and therefore we encourage you to update your information in your own account in case any changes have occurred. We have listed below the rights that you may be able to exercise with respect to the processing of your Personal Information, subject to applicable law. We take every reasonable step to ensure that the Personal Information that we process is limited to the Personal Information that is reasonably required in connection with the purposes set out in this Privacy Notice. If you are a resident of or located within the EEA, UK, or Switzerland, you have the following rights under the GDPR: * The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Information by contacting us at the contact information below. * The right of rectification. You have the right to correct any inaccuracies in the personal information we process about you. * The right to object. Subject to limitations, you have the right to object to our processing of your Personal Information. * The right of restriction. You have the right to request that we restrict the processing of your Personal Information. * The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format. *The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your Personal Information. @h5 Legal Basis for Processing Personal Information We rely on the following legal basis for processing your Personal Information: * Processing of your Personal Information that you provide to us when you interact with our Services, such as commenting on our community blog, watching our videos or making a purchase, is necessary to respond to or implement your request prior to entering a contract with us or to perform your agreement with us. * We use account-related data to set up accounts for users in our platform and to administer and support those accounts (such as usernames, email address and billing information), provide you with access to the Products and Services, contact you regarding your use of the Products or Services or to notify you of important changes to the Products or Services. Such use is necessary for the performance of the contract between you and us. * Depending on jurisdiction, we will send you information by email on our new services or other promotions only with your consent or if you elect to receive those communications. If you do not provide us with your consent to the processing of your Personal Information for this purpose, we will not send you this information. You have the right to withdraw your consent at any time as described below. In addition, we use information received for our legitimate interest in monitoring the efficacy of our marketing efforts, respond to inquiries about our business and services, and promote our service offerings. * Our processing of data relating to your use of the Products and Services, described above, is necessary for the following legitimate interests: 1. Understanding how the Products and Services are being used by you. 2. Improving your experience on our Products and Services offerings. 3. Confirming the identity of students and educators/administrators. 4. To detect and prevent potential security issues in connection with our Products. 5. Aggregating and/or anonymizing the information that we collect through our Products or Services and using this information for our business purposes, as described above. * When we process your Personal Information for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your Personal Information for activities where our interests are overridden by the impact on you, unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object to processing that is based on our legitimate interests, as further described below. @h4 Retention of Personal Information Capstone will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Notice. The criteria used to determine our retention periods include (i) the length of our ongoing relationship with a particular user of the Products and Services, (ii) the period of time necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), and (iii) the length necessary to resolve disputes and enforce our legal agreements and policies. @h4 Exercising Your Rights Under GDPR If applicable and subject to exceptions, you may exercise any of your rights under the GDPR by submitting a verifiable data subject request to us by using this form or the contact details below. You may make a request related to your Personal Information or on behalf of someone for which you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of the EEA by including your country of citizenship or residence in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency in the EEA in order to obtain the information. Once we have received your request, we will review it and contact you within 30 days of our receipt of your request, but we will notify you of any delay and, in any event, will reply within three (3) months. Please note that we may ask you for information necessary to verify your identity before responding to such requests, and we may deny your request if we are unable to verify your identity or authority to make the request. You will not typically need to pay a fee to exercise any of your rights under the GDPR. But we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances. Should you wish to raise a concern about our use of your data (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority; however, we hope that we can assist with any queries or concerns you may have about our use of your Personal Information first by contacting us as follows: Data Privacy Administrator Coughlan Companies, LLC dba Capstone 1710 Roe Crest Drive North Mankato, MN 56003 Email: [url=mailto:privacy@capstonepub.com]privacy@capstonepub.com[/url] If in the United Kingdom: Raintree 264 Banbury Road Oxford, OX2 7DY United Kingdom Email: [url=mailto:feedback@raintree.co.uk]feedback@raintree.co.uk[/url] Data Protection Officer: Ametros Group Ltd Lakeside Offices, Thorn Business Park Rotherwas Industrial Estate Hereford Herefordshire England HR2 6JT 0330 223 2246 Email: [url=mailto:dpo@ametrosgroup.com]dpo@ametrosgroup.com[/url] Website: [url=www.ametrosgroup.com]www.ametrosgroup.com[/url] EU Representative: Ametros Ltd Unit 3D North Point House North Point Business Park New Mallow Road Cork Ireland Email: [url=mailto:gdpr@ametrosgroup.com]gdpr@ametrosgroup.com[/url] Website: [url=www.ametrosgroup.com]www.ametrosgroup.com[/url]
@h4 Your California Privacy Rights This section of our Privacy Notice applies to “consumers” who reside in California, as defined by the California Consumer Privacy Act (“CCPA”). We adopt this section to comply with the CCPA, including as amended by the California Privacy Reform Act (“CPRA”). This Section applies to our processing activity when we are acting as a “business” under the CCPA—meaning that we control the purposes and means of processing your personal information. Some of the personal information we collect may be subject to other data protection laws (such as the Fair Credit Reporting Act) and may be exempt from some or all requirements under the CCPA. If you are a California resident, you may be able to exercise the following rights. We will honor requests received to the extent required by applicable law and within the time provided by law. @h5 Right to Access and Information Regarding Personal Information You have the right to request that we disclose to you the categories and specific pieces of Personal Information we have collected about you. Specifically, you have the right to request that we disclose the following to you, in each case, for the twelve-month period preceding your request: * The categories of Personal Information we have collected about you; * The categories of sources from which the Personal Information is collected; * Our business or commercial purpose for collecting or selling Personal Information; * The categories of third parties with whom we share Personal Information; * The specific pieces of Personal Information we have collected about you; * The categories of Personal Information about you, if any, that we have disclosed for monetary or other valuable consideration and the categories of third parties to which we have disclosed the information, by category or categories of Personal Information for each third party to which we disclosed the Personal Information; and * The categories of Personal Information about you that we disclosed for a business purpose. @h5 Right to Deletion of Personal Information You have the right to request that we delete Personal Information that we have collected about you. There may be certain exceptions to our obligation to delete your information such as if you have an existing account or transaction with us or if we have a legitimate business reason to keep your information. @h5 Right to Correct Inaccurate Information If we maintain inaccurate personal information about you, you have the right to request that we correct that inaccurate personal information, considering the nature of the personal information and the purposes of the processing of the personal information. @h5 Right to Opt-Out The CCPA also gives consumers the right to opt-out of the (1) sale of their personal information, (2) “sharing” of their personal information for cross-context behavioral advertising, and (3) use of their personal information for certain types of automated decision making. The CCPA also gives consumers the right to limit the use or disclosure of their sensitive personal information, when it is used for certain purposes. Because Capstone does not engage in any of the foregoing activities in connection with the Products and Services, those rights are not available. To that end, in the prior 12 months, Capstone has not sold or “shared” (for cross-context behavioral advertising) any personal information collected from a consumer in connection with the Products. Likewise, Capstone does not have actual knowledge that it sells or shares the personal information of consumers under 16 years of age in connection with the Products. @h5 Right to Non-Discrimination We may not discriminate against you because you have exercised any of the aforementioned rights, including by: * Denying you goods or services; * Charging different prices or rates for goods or services, including using discounts or other benefits or imposing penalties; * Providing you a different level or quality of goods or services; or * Suggesting that you will receive different price or rate for goods or service or at a different level or quality of goods or services. @h5 Notice of Financial Incentives As permitted by the CCPA, we may offer you certain financial incentives and benefits by joining our Capstone Rewards loyalty program. The information that we collect for enrollment in the program (listed above) allows us to tailor our communications and products and services suggestions for you. This, in turn, helps us establish a stronger relationship with you – something we at Capstone value. If you participate in the Capstone Rewards program, there are two types of financial incentives: * [b]Points[/b]. You can earn points when you purchase products from our online store that can be used to discount the price of future purchases with us. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value. We estimate the value of personal information we request from our Capstone Rewards program customers by comparing the amount spent by Capstone Rewards program customers to similarly situated customers who do not participate in the Capstone Rewards program over a 12-month period. * [b]Discounts.[/b] We may also send you promotions to discounted products and services. The value of these discounts varies and depends on the type of product you are buying. Participation in the Capstone Rewards program is voluntary and requires your prior opt-in consent, which you may revoke at any time. If you wish to leave the Capstone Rewards program, please reach out to us using the information in the Contact Us section below. For full program details, please visit [url=/support/legal/rewards-terms-and-conditions]https://www.capstonepub.com/legal/rewards-terms-and-conditions[/url]. @h5 Personal Information We Collect about California Consumers We collect certain types of Personal Information about you during your relationship with us, as stated above. In particular, we collected the following categories of Personal Information from California consumers within the last twelve (12) months:
The business and commercial purposes for which we collect and disclose these categories of personal information are set forth above in the sections titled “How We Use Your Information” and “Third Parties to Whom We Disclose Your Information.” @h5 Data Sharing for Direct Marketing Purposes California Civil Code § 1798.83 further permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. If you are a California resident, you may ask us to refrain from sharing your personal information with certain of our affiliates and other third parties for their marketing purposes. Please tell us your preference by contacting us at privacy@capstonepub.com. @h4 Notice for Nevada Residents Under Nevada law, Nevada “consumers” may request that “operators” of internet sites and online services refrain from the “sale” of their “covered information” to third parties (as such terms are defined under Nevada law). “Covered information” includes first and last name, address, email address, and phone number, or an identifier that allows a specific person to be contacted either physically or online. As discussed above, we share your information with certain third parties that we believe can provide you with offers and promotions for products and services of interest to you and in the other ways described above. We do not believe this constitutes a sale under Nevada law. @h4 Residents of Other States The laws in other states (e.g., Colorado, Connecticut, Oregon, Iowa, Nebraska, Minnesota, Texas, Virginia, etc.) may afford individuals who reside in those states with certain rights regarding their personal information. [b]A. Personal Information We Collect and Process [/b] The sections above entitled, “Personal Information We Collect About You,” “How We Use Your Information,” and “Third Parties to Whom We Disclose Your Information,” describe the categories of personal information processed by us, the purposes for processing, the categories of personal information disclosed to third parties, and the categories of third parties to whom we disclose personal information. [b]B. Your Personal Information Rights [/b] Subject to exceptions, the laws of your state of residence may provide you the right to: * Confirm whether we are processing your personal information and/or to access such data; * Update or correct inaccuracies in your personal information, considering the nature of the personal information and the purposes of the processing of your personal information; * Delete personal information provided by or obtained about you; * Obtain a copy of the personal information provided to or processed by us, in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance, where the processing is carried out by automated means; * Obtain a list of the third parties to whom we have disclosed personal information; * Be free from discrimination for exercising any of the rights described in this section; and/or * Opt out of the sale of your personal information, the processing of your personal information for the purposes of targeted advertising, or the use of your personal information for automated decision-making or automated profiling in furtherance of decisions that produce legal or similarly significant effects. Capstone does not engage in the sale of personal information for monetary consideration or the automated profiling in furtherance of decisions that produce legal or similarly significant effects concerning consumers. As a result, the right to opt out of such activities may not be available. Capstone does, however, use personal information for the purposes of targeted advertising. The laws of the state where you reside may also provide rights with respect to “sensitive personal information.” Capstone does not collect or process any “sensitive personal information” as defined by those states’ laws in connection with the Products and Services. As such, the rights attendant to such information are not available To the extent permitted by the state where you reside, you may submit a request for any of the foregoing rights by following the instructions below in the section titled “Request to Exercise Your Rights.” In the event Capstone declines a request to exercise the foregoing rights, depending on the applicable law, you may have the right to appeal the decision. You can do so by contacting us at privacy@capstonepub.com. You may also be entitled to report the matter to the appropriate regulator in your state. @h4 Residents of Canada If you reside in Canada, various Canadian laws, including Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”), may provide you certain rights with respect to your personal information, including the right to request information about the collection, use, or disclosure of your personal information, to request access to your personal information, and to challenge the accuracy and completeness of your personal information and have it amended as appropriate. If you are a Canadian resident and would like to make a request regarding your personal information, please follow the instructions in the section titled “Request to Exercise Your Rights.” We will attempt to respond to your request as quickly as possible but may ask you to provide additional information to enable us to locate the personal information or determine how it has been used or disclosed. We will provide you access, as appropriate, at minimal or no cost to you. @h4 Other Global Privacy Laws We are committed to protecting personal information in accordance with all applicable privacy and data protection laws. To that end, we endeavor to meet requirements under other international privacy laws, such as Brazil’s Lei Geral de Proteção de Dados (LGPD), South Africa’s Protection of Personal Information Act (POPIA), and other applicable privacy frameworks where our users reside. Depending on your location, you may have specific rights related to your personal data, such as the right to access, correct, delete, or limit the processing of your information, as well as the right to opt out of certain types of data uses (such as targeted advertising). We will honor these rights in accordance with the laws that apply to you and provide clear mechanisms for exercising them. @h4 Requests to Exercise Your Rights You or your authorized agent may make a request to access, correct, delete or opt-out of the disclosure of your Personal Information for business purposes. You may also make a verifiable consumer request on behalf of your minor child if you believe we have received their information inadvertently. You may request to exercise the aforementioned rights by: * For Customers in any jurisdiction, submitting [url=https://privacyportal.onetrust.com/webform/ad87e15d-773f-4bc4-a5e8-781894826023/2516ee11-431c-4618-b7b6-8e632216ca3b]this form[/url] * For Cooperative Educational Services in any jurisdiction, submitting [url=https://privacyportal.onetrust.com/webform/ad87e15d-773f-4bc4-a5e8-781894826023/2e8487d7-181d-4e15-a4da-00d1e023fe98]this form[/url] * Emailing us at [url=mailto:privacy@capstonepub.com]privacy@capstonepub.com[/url] Please Note: If you are a parent, student or teacher within a school or district account, please contact your school or district administrator to submit your request. Your request must include your name, e-mail address, mailing address, phone number, the nature of your inquiry and the context in which we may have received your information. Please note that we may take additional steps, and request additional information, to verify your identity and residency before granting you access to information or acting on your request to exercise your rights, as required or permitted by law. To protect the privacy and security of consumers, a verifiable request must: * Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of such consumer; and * Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. If you use an authorized agent, we may require proof of written authorization you have given to make the 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. We may limit our response to your exercise of the above rights as permitted by law. You may only make a verifiable consumer request for access or data portability twice within a twelve (12)-month period. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you or the consumer on whose behalf you are making the request. We will confirm receipt of the request within 10 business days describing our verification process. We will respond to your request within 45 days or let you know if we need additional time, in which case we may extend our response period by an additional 45 days and will explain the reasons for any such extension. For data portability requests, we will select the format of our response; the format will be readily useable and should allow you to transmit the information from one entity to another. We will not charge a fee to process or respond to a 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 the request. @h4 Changes to This Privacy Notice We may change this Privacy Notice at any time. We will post all changes to this Privacy Notice on this page and will indicate at the top of the page the effective date of the modified notice. We therefore encourage you to refer to this page on an ongoing basis so that you are aware of our current privacy notice. If required by the applicable law, we will notify you of the changes. By continuing to use the Products or the Services or providing us with information following such a replacement Notice being uploaded, you agree that you will be deemed to have agreed to be bound by the amended Privacy Notice. @h4 Contact Us If you have any questions or suggestions regarding this Privacy Notice, please contact us at: Data Privacy Administrator Coughlan Companies, LLC dba Capstone 1710 Roe Crest Drive North Mankato, MN 56003 Email: [url=mailto:privacy@capstonepub.com]privacy@capstonepub.com[/url] Contact number: 888-262-0705 If in the United Kingdom: Raintree 264 Banbury Road Oxford, OX2 7DY United Kingdom Email: [url=mailto:feedback@raintree.co.uk]feedback@raintree.co.uk[/url] If you believe we have not addressed your concern satisfactorily, you may contact our COPPA Safe Harbor provider at: iKeepSafe Safe Harbor Program Email: [url=mailto:COPPAPrivacy@ikeepsafe.org]COPPAPrivacy@ikeepsafe.org[/url]