CODECAMPUS ACADEMY LLC

PRIVACY POLICY

Last Modified: May 25, 2018

1. Scope - Privacy Policy, Terms of Service, and Third Party Links

1.1. Privacy Policy. This Privacy Policy (this "Privacy Policy") applies to information we collect or use on websites, including, www.codecampus.com, applications, products, features, services, or any portion thereof (collectively, the "Service"), owned or controlled by CodeCampus Academy LLC, a Delaware limited liability company, or its affiliated companies ("CodeCampus" or " we" or "our" or "us"). Affiliated companies are entities that control, are controlled by or are under common control with CodeCampus.

1.2. Terms of Service. This Privacy Policy and the CodeCampus Terms of Service ("Terms of Service"), which can be found at www.codecampus.com/terms, and is incorporated herein by reference, are an agreement (collectively, this "Agreement") between CodeCampus and you ("You" or "your" or "you"), a user of the Service. By accessing or using the Service, you acknowledge and agree to this Privacy Policy and the Terms of Service. If you choose to not agree with the Privacy Policy or the Terms of Service, you may not use the Service.

1.3. Third Party Links to Other Websites or Services. The Service contains third party links to other websites or services. Please be aware that we are not responsible for the content or privacy practices of such other third party websites or services. We encourage our users to be aware when they leave CodeCampus' Service and to read the privacy statements of any other site that collects personal information.

2. Information Collection

2.1. Information You Provide. We may collect information that identifies you ("Personal Information") when you use the Service or register for an account. The types of Personal Information that we may collect include:

(a) Information that you provide to us when you register for an account, such as your name, the school you work at, and your email address;

(b) Information that you provide to us when you purchase a product or service, including, without limitation, payment card and billing information;

(c) Information that you provide if you use the Service to upload, share, or communicate any content or information, including photos, images, videos, text, social network accounts, or other Personal Information that you may include about yourself or others;

(d) Information that you publicly post via social media networks, forums, blogs, message boards, chat rooms or similar functionality is public information that we, or others, may share or use in accordance with the law;

(e) Information that you provide to us if you participate in a sweepstakes, contest, rewards program, or other promotion;

(f) Information that you provide if you email, phone, contact or communicate with us or our third party service providers, such as your email address or phone number.

2.2. Information We Collect (a) Traffic and usage information generated from your visit to the Service, including traffic data, pages you visit, browser information, operating system, IP address, cookie information, and the type of device that you use to access the Service;

(b) In connection with your visit or use of the Service, we may automatically collect information about our users, such as the numbers and frequency of users and their characteristics and information about similar groups of users, certain age groups or users that live in a particular geographical area. This data is only used in the aggregate as a statistical measure and not in a manner that would identify you personally. Aggregate information generally is collected through the use of cookies and beacons;

(c) Information from public databases and third parties;

(d) We may target and track the videos you view on the Service. You consent to our tracking of your video viewing through the Service or third party social media for up to two (2) years or as permitted by applicable law;

(e) When you access or use the Service, or any portion thereof, we may collect physical location information that is sufficiently precise to allow us to locate a specific person or device ("Location Information"). We only collect Location Information with your permission (e.g., such as when you agree to provide it to us after you initially access or use the Service). We may use Location Information and provide it to third parties to provide you with content and services that are relevant to a particular location, such as advertising, search results, and directions.

3. Tracking Technologies We Use

We may use one or more of the following tracking technologies, and similar future tracking technologies, to automatically collect information: cookies, local shared objects, web beacons, unique telephone numbers, general log information and referral information from third-party services.

3.1. "Cookies" are alphanumeric identifiers that we transfer to your computer's hard drive through your Web browser to enable our systems to recognize your browser and tell us how and when pages in the Service are visited and by how many people. Our cookies do not collect personal information, and we do not combine information collected through cookies with other personal information to tell us who you are or your screen name or e-mail address. The "Help" portion of the toolbar on the majority of browsers will direct you on how to prevent your browser from accepting new cookies, how to command the browser to tell you when you receive a new cookie, or how to fully disable cookies. We recommend that you leave the cookies activated because cookies allow you to use many features of the Service.

3.2. "Web beacons," also known as an Internet tags, pixel tags or clear GIFs, link web pages to web servers and their cookies. Web beacons can be embedded in web pages, videos, or emails, to collect certain types of information from your browser, check whether you have viewed a particular web page or email message, and determine, among other things, the time and date on which you viewed the content, the IP address of your computer, and the URL of the web page from which the content was viewed.

3.3. "Local shared objects," sometimes known as Flash cookies, may be used to store your preferences or display content based upon what you have viewed on various websites to personalize your visit.

4. How We Use Your Information

We may use the information that we collect for any of the following purposes:

4.1. To provide, operate, maintain, improve, and promote the Service;

4.2. To enable you to access and use the Service, including uploading, downloading, collaborating and sharing content, photos, images, videos and information, with other users or third parties;

4.3. To process and complete transactions, and send you related information, including purchase confirmations and invoices;

4.4. To send transactional messages, including responding to your comments, questions, and requests; providing customer service and support; and sending you technical notices, updates, security alerts, and support and administrative messages;

4.5. To send promotional communications, such as providing you with information about services, features, newsletters, offers, promotions, contests, events and sending updates;

4.6. To monitor and analyze trends, usage, and activities in connection with the Service and for marketing, advertising, administrative, analytical, research, optimization, and other purposes. For example, we may use statistical analyses of usage data in order to measure interest in the various areas of the Service, for development purposes and to inform advertisers and partners in aggregate and anonymous terms about consumers who click on their advertising or other messages. IP addresses are also used for systems administration and troubleshooting purposes.

4.7. To investigate and prevent fraudulent transactions, unauthorized access to the Service, and other illegal activities;

4.8. To personalize the Service's content, features or advertisements;

5. Information Sharing

5.1. Payment Processors. We share your payment information with payment services providers to:

(a) Process payments;

(b) Prevent, detect and investigate fraud or other prohibited activities;

(c) Facilitate dispute resolution such as chargebacks or refunds;

(d) For other purposes associated with the acceptance of credit or debit cards. We may share your credit or debit card number with payment services providers or card networks to monitor card transactions at participating merchants and track redemption activity for the purposes of providing card-linked services.

5.2. Authorized Personnel. Our employees, agents, consultants, contractors, or other authorized personnel, may have access to user information as necessary in the normal course of our business.

5.3. Business Transfers. In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the business assets that is transferred. Moreover, if the Service or CodeCampus, or substantially all of its assets, were acquired, liquidated, or dissolved, user information would be one of the assets that is transferred.

5.4. Government, Law Enforcement or Third Parties. We may disclose any information, including, without limitation, Personal Information that we deem necessary, in our sole discretion and without your prior permission, to comply with any applicable law, regulation, legal process or governmental request. We also may exchange information, including, without limitation, Personal Information, with other companies and organizations to protect the rights, property, or safety of CodeCampus and its affiliates, personnel, users, third parties, or others. We reserve the right to disclose a user's Personal Information if we believe, in good faith, that the user is in violation of the Terms of Service, even without a subpoena, warrant or other court order.

5.5. Social Media Networks. We may include applications or widgets from social media networks that allow interaction or content sharing by their users. These widgets, such as a Facebook "Share" or "Like" button, are visible to you on the web page you visit. Integration between the Service and social media networks such as Facebook, Twitter and others may allow social media networks in which you participate to collect information about you, even when you do not explicitly activate the network's application or widget. Please visit the applicable social media network's privacy policy to better understand their data collection practices and choices they make available to you. The privacy policy of the social media network controls the collection, use and disclosure of all personal information transmitted to that network.

6. Choice and Opt-Out

We provide you the ability to exercise certain controls and choices regarding our collection and use of your information.

6.1. Choice. In accordance with local law, your controls and choices may include:

(a) You may correct, update and delete your account information, as described below;

(b) You may change your choices for subscriptions and newsletters;

(c) You may choose whether or not to receive offers from us;

6.2. Opt-out. We may also use tracking technologies to collect information about your visits over time. The Network Advertising Initiative (the "NAI") is a cooperative group of ad serving providers. The NAI has developed a set of privacy principles to which its members adhere. The NAI is committed to providing consumers with clear explanations of Internet advertising practices and how they affect you and the Internet generally. For more information about the NAI, third party ad servers generally and the opt-out options offered through the NAI, visit http://www.networkadvertising.org/index.asp.

7. Accessing and Correcting Your Information

If you have a CodeCampus account, you can help ensure that your contact information and preferences are accurate, complete, and up to date by logging by emailing us at support@codecampus.com. For other personal information we hold, we will provide you with access for any purpose including requesting that we correct the data if it is inaccurate or delete the data if we are not required to retain it by law or for legitimate business purposes. We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law.

8. Security of Your Information.

8.1. Security Measures. We have put in place physical, electronic, and managerial procedures designed to help prevent unauthorized access, to maintain data security, and to use correctly the information we collect online. These safeguards vary based on the sensitivity of the information that we collect and store.

8.2. No Security Guarantees. Although we take appropriate measures to safeguard against unauthorized disclosures of Information, we cannot assure you that Information will never be disclosed, altered or destroyed in a manner that is inconsistent with this Privacy Policy.

9. Changes to the Privacy Policy . Although most changes are likely to be minor, we may change our Privacy Policy from time to time, and in our sole discretion. We encourage visitors to frequently check this page for any changes to the Privacy Policy. Your continued use of the Service after any change in this Privacy Policy will constitute your acceptance the changes.

10. California Privacy Rights and Do Not Track Disclosures

If you are a California resident, you may have certain additional rights.

10.1. Privacy Rights. California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your Personal Information by us to third parties for the third parties' direct marketing purposes. California Business and Professions Code Section 22581 permits registered users who are minors to request and obtain deletion of certain posted content. To make any such requests, please email us at support@codecampus.com or contact us at the address below.

10.2. Do Not Track DisclosuresCalifornia Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how CodeCampus responds to "Do Not Track" browser settings. We do not currently take action to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.

11. Users From Other Jurisdictions

By using the Service, you acknowledge that you accept the practices and policies outlined in this Privacy Policy and consent to having your data transferred to and processed on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction. If you do not accept this Privacy Policy, please do not use the Service. The Service is controlled and operated by CodeCampus from the United States. If you are not a resident of the United States or you are located outside the United States and choose to use the Service or provide information to us, please note that we will transfer the information, including Personal Information, to the United States and process it there. Your acceptance of this Privacy Policy, followed by your submission of such information represents your agreement and consent to that transfer. We do not represent or warrant that the Service, or any portion thereof, are appropriate or available for use in any particular jurisdiction. Those who choose to access the Service do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. You also are subject to United States export controls in connection with your use of the Service and are responsible for any violations of such controls, including, without limitation, any United States embargoes or other federal rules and regulations restricting exports. We may limit the availability of the Service, in whole or in part, to any person, geographic area or jurisdiction that we choose, at any time and in our sole discretion.

12. EU Members' Rights

If you are habitually located in the European Union, you have the right to access, rectify, download or erase your information, as well as the right to restrict and object to certain processing of your information. While some of these rights apply generally, certain rights apply only in certain limited circumstances. We describe these rights below:

Access and Porting You can access much of your information by logging into your account. If you require additional access, contact us at support@codecampus.com.

Rectify, Restrict, Limit, Delete You can also rectify, restrict, limit or delete much of your information by logging into your account. If you are unable to do this or wish to delete data other than project data, please contact us at support@codecampus.com. CodeCampus will generally respond to your request within 7 business days.

Object Where we process your information based on our legitimate interests explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons.

Revoke consent Where you have previously provided your consent, such as to permit us to send marketing email to the adult-provided email, you have the right to withdraw your consent to the processing of your information at any time. For example, you can withdraw your consent by updating your settings. In certain cases, we may continue to process your information after you have withdrawn consent if we have a legal basis to do so or if your withdrawal of consent was limited to certain processing activities.

Complain Should you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority.

13. Contact Information

If you have any questions, feedback or to report a violation regarding the Privacy Policy, you may email us at support@codecampus.com or contact us by mail addressed to:

CodeCampus Academy LLC
1691 Kettering, Irvine, CA 92614