PRIVACY POLICY

Updated October 9, 2023

This notice describes the privacy policy of bookroo.com (the "Site"), the service operated and owned by Vermilion Labs LLC ("Bookroo"). References herein to "we", "us", and "our" refer to Bookroo and/or its affiliates. References herein to "you", "your", and "user" refer to all individuals and/or entities accessing Bookroo for any reason. If you have questions or concerns regarding this statement, you should contact us at support@bookroo.com. This Privacy Policy describes how your Personal Information (defined below) is collected, used, and shared when you visit or make a purchase from the Site.

PERSONAL INFORMATION WE COLLECT

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”

We collect Device Information using the following technologies:

  • “Cookies,” which are data files containing identifiers (strings of letters and numbers) that are sent by a web server to a web browser and stored by the browser. The identifiers are then sent back to the server each time the browser requests a page from the server. Cookies may be either "persistent" cookies or "session" cookies. A persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie will expire at the end of the user session, when the web browser is closed. Cookies do not typically contain any information that personally identifies a user, but Personal Information that we store about you may be linked to the information stored in and obtained from cookies. For more information about cookies, including how to disable cookies, visit http://www.allaboutcookies.org.
  • “Log files,” which track actions occurring on the Site and collect data, including your IP address, browser type, Internet service provider, geolocation information, referring/exit pages, and date/time stamps.
  • “Web beacons,” “tags,” and “pixels,” which are electronic files used to record information about how you browse the Site.

Additionally when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers), email address, and phone number. We refer to this information as “Order Information”.

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information.

HOW DO WE USE YOUR PERSONAL INFORMATION?

We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use Order Information to:

You consent to the disclosure of certain personally identifiable information, as well as listing and order information, by us to third-party fullfillment centers, service providers, and other third parties in connection with the processing, fulfillment, and transportation required by our Service (as defined in our Terms of Service). We do not control the privacy policies of such fulfillment centers, service providers, or third parties, and you are subject to the privacy policies of those parties, as applicable.

  • Communicate with you;
  • Screen our orders for potential risk or fraud; and
  • When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally, to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site and to assess the success of our marketing and advertising campaigns).

SHARING YOUR PERSONAL INFORMATION

We share your Personal Information with third parties to help us use your Personal Information as described herein. For example, we use Cratejoy to power our online store—you can read more about how Cratejoy uses your Personal Information here: https://www.cratejoy.com/sell/privacy/. We also use Google Analytics to help us understand how our customers use the Site—you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

Bookroo may provide services, including services to libraries, academic institutions, publishers, and other organizations or third parties, with or using data from the Site and Site users. Bookroo may also provide access to the same information via data feeds.

These services include aggregate, anonymous and anonymized metadata, such as popularity, average ratings, and tags. No personally-identifiable information is shared with this data.

Our services also include some user-provided reviews. Such sharing includes usernames and the content of user reviews. Members can change their settings for the sharing of reviews, including options to keep reviews private, on their profile account when they are logged in.

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

ADVERTISING

This Site is affiliated with CMI Marketing, Inc., d/b/a CafeMedia (“CafeMedia”) for the purposes of placing advertising on the Site, and CafeMedia will collect and use certain data for advertising purposes. To learn more about CafeMedia’s data usage, click here: www.cafemedia.com/publisher-advertising-privacy-policy.

BEHAVIOURAL ADVERTISING

As described herein, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by using the links below:

  • Facebook: https://www.facebook.com/settings/?tab=ads
  • Google: https://www.google.com/settings/ads/anonymous
  • Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

DO NOT TRACK

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

YOUR RIGHTS

Upon request, we will provide you with information about whether we hold any of your user information.

Registered users may change the information stored in their user profile such as image, name, and password at any time by visiting their user profile page at https://bookroo.com/settings. Users can also control which actions, if any, will appear on their update feeds.

All users may elect to stop receiving email marketing material from us or on behalf of external third party business partners by following instructions at the end of any marketing email. To opt out of other forms of marketing, please contact us using the details below. You may not opt out of service-related communications (e.g., account verification, changes/updates to features of the service, technical and security notices).

Your rights and controls with respect to the user information that may be collected, used, or shared in connection with cookies are outlined above. You can modify your cookie preferences by following the procedure outlined above. If you have any questions, please contact us as outlined below.

You may, of course, decline to submit personally identifiable information through the Site, in which case Bookroo may not be able to provide certain services to you. You may request to delete or modify your personal account and/or any user information you may have voluntarily submitted to us if you wish to do so. In addition, you may request to have user information maintained by us deleted subject to the Data Retention section below.

California Residents Only: If you are a California resident, you are entitled to request notice of certain information about the user information that we may share with third parties for marketing purposes (e.g., the categories of user information shared, and contact information of applicable third parties), as well as request that we disclose to you what Personal Information we collect, use, disclose and sell about you, and the right to request deletion of Personal Information we collect or maintain about you. If you would like to exercise any of these rights, please contact us as described below and title your request as follows or in a similar manner: "CCPA – California Resident Request". You have the right to opt out of the sale of your user information (which California law defines to possibly include sharing user information with third parties to deliver targeted advertising). To exercise your Do Not Sell right to opt out of targeted advertising, please use the opt out links in the section “Behavioral Advertising.” You also have the right to not be treated in a discriminatory manner for having exercised your rights regarding your privacy rights under the California Consumer Privacy Act (CCPA).

If you are a European resident, you have the right to access Personal Information we hold about you and to ask that your Personal Information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below. Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.

CHILDREN'S PRIVACY POLICY

Except as noted below under School Accounts, our service and its content are not directed at children under the age of 13, and Bookroo does not knowingly collect or solicit any personal information from anyone under the age of 13 or knowingly allow such persons to register for our service. In the event that we learn that we have collected personal information from a child under age 13, we will take steps to remove that information from our databases as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at the address listed below.

When you create an account, you also have the option to create individual reader profiles for other members of your family, including your children. Do not include any personally identifying information in usernames you assign to reader profiles for your children. You can choose whether your reader profiles are viewable or kept private from other site visitors and users. If you would like these reader profiles to be private, please select the option to keep them private.

SCHOOL ACCOUNTS

While we operate our site as a general audience website that does not knowingly collect information from children under 13, we make access to our site available to K-12 students and schools. Therefore, we provide this Children’s Privacy Policy to explain our privacy practices with respect to children under 13 who access and use our services, and through this Privacy Policy, we provide each school with all the notices required under the Children’s Online Privacy Protection Act (“COPPA”).

Access to our service is only available upon request by a school and only for the purposes of performing services on behalf of the school. Schools that provide access to our service acknowledge that they provide any disclosures and receive any consents necessary for us to collect Personal Information directly from students (“Student Personal Information”) under 13 in accordance with the "school consent" mechanism allowed under COPPA.

To prevent unauthorized collection of Student Personal Information, students under 13 cannot independently access our services without access to an account from the schools that request our services.

Student Personal Information may include:

  • Student login ID and password
  • First and last name;
  • The class and school where a student is enrolled;
  • Student-generated content, such as responses to questions, prompts and assignments;
  • Data generated from student activity within the site, including answers provided, errors, hint requests, preferences, timing information, progress within the system, and inferences made from the this data about student knowledge;
  • Feedback about any of our products and services; and
  • Assessment scores used to customize instruction.

We do not enable children under 13 to make their Personal Information publicly available.

In addition, we may automatically collect information about the devices children under 13 use to interact with our services. The information we automatically collect may include IP address, device identifier, web browser type and version, pages and activities viewed, and the date and time of use. Any usage information, device identifier, or other persistent identifier we collect is used for the sole purpose of providing support for internal operations.

Our collection, use, and disclosure of Personal Student Information is governed by, and in compliance with, the provisions of the Family Educational Rights and Privacy Act (“FERPA”), the Protection of Pupil Rights Amendment (“PPRA”), COPPA, and applicable state laws which relate to the collection and protection of Personal Student Information and educational records. We access and process Student Personal Information for the purposes of providing an outsourced institutional function pursuant to FERPA 34 CFR Part 99.31(a)(1). In offering access to our site, we will be considered a school official with a legitimate educational interest in the Student Personal Information, under the direction and control of school.

All Student Personal Information collected, generated or received by us is and will continue to be the property of and under the control of the relevant school or person who provided such data (such as the student or parent/guardian).

We collect this Student Personal Information about children under 13 for the use and benefit of teachers or school or school district administrators, and for no other commercial purpose. We limit the use of Student Personal Information about children under 13 to the educational context authorized by the school. We will not use any Student Personal Information collected about children under 13 to advertise or market to students or their parents. We will never condition a student’s participation in our service on the child’s disclosure of more Student Personal Information than is necessary to participate in the activity.

Uses of Student Personal Information collected from children under 13 include:

  • Personalizing the teaching and learning resources to improve student instruction and meet individual student needs;
  • Providing reports to teachers or school or school district administrators at the student, class, school, or district level;
  • Supporting teachers or schools or school district administrators implementing our services;
  • Monitoring the use of our services and performing such analyses as might be necessary or helpful in improving product performance, efficiency, and security;
  • Researching how students use our services and performing analysis directed at improving the educational effectiveness of our services;
  • Providing reports to students, parents or guardians; and
  • Helping students reset their passwords.

We may rely on third party service providers who provide support for the internal operations of our services, such as hosting the website, designing and/or operating our digital properties’ features, tracking analytics, or performing other administrative services. These third party service providers are held to the same obligations we are with regard to Student Personal Information from children under 13.

We do not permit third party advertising networks to collect information from Student Accounts about your use of our service over time and across websites for the purpose of serving targeted advertising, and we will never use Student Personal Information for targeted advertising.

We do not rent or sell Student Personal Information for marketing purposes, and we will never share or sell Student Personal Information with third parties for marketing purposes.

We may share information in an aggregated and/or anonymous form that does not reasonably identify an individual or school. For example, we may use and share aggregate or anonymized data for analytics purposes and to study and improve our service and user functionality. In addition, for research and other purposes, we may transfer de-identified data to third parties. For example, we may share information such as ratings and demand.

We acknowledge the rights of parents and legal guardians to review any educational data pertaining to their children under FERPA, and you always remain in control of the information you provide to us. To request information pertaining to a student or for any questions related to Student Personal Information, you must contact your child’s school. We promptly route requests made by parents or legal guardians to the relevant school, and we will assist the school as needed to provide parents and legal guardians access to the requested information within a reasonable time frame.

DATA RETENTION

We will retain your user information for as long as your account is active or as needed to provide you the service, unless you have revoked your consent or requested to delete certain user information; and we may retain certain user information for specific legitimate interests where we have an ongoing business need (for example, relating to core service functionalities (such as fraud-prevention and account recovery), or to comply with applicable tax, legal or accounting requirements). When we have no ongoing legitimate business need to use your user information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in back-up archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information using the contact information below.

Following termination or deactivation of your account, we may retain information (including your profile information) and User Content (as defined in our Terms of Service) for a commercially reasonable time for backup, archival, and/or audit purposes.

CHANGES

We reserve the right to change our Privacy Policy at any time. We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

CONTACT US

For more information about our privacy practices or if you have questions, please contact us by e‑mail at support@bookroo.com or by mail using the details provided below:

Bookroo
Re: Privacy Compliance Officer
971 S University Dr #1020, Provo, UT 84601

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