PRIVACY POLICY

1.                Purpose

This Privacy Policy ("Policy") applies to TorranceLearning's website and web-enabled applications (together, the "Platform") operated by Megan Torrance, Inc. ("us" or "we").This Policy identifies the personally identifiable information ("PI") and other anonymous information ("AI") we gather (collectively, "Information") and how we use such Information. Please contact us using the information below if you have any questions about this Policy.

2.                Acceptance of the Policy

You accept this Policy by using any part of the Platform, including by setting up or registering a user account.

3.                Changes to Policy

If we make any significant changes to this Policy, we will notify you by email or flag this Policy on the Platform as updated. You agree to our use of electronic communications with you for purposes of this Policy. If you do not agree to the changes to this Policy, we will continue to maintain and use PI previously collected in accordance with the Policy in force as of that date, but we reserve the right to terminate your further use of your account and your access to any Platform functionality.

4.                Personally Identifiable Information

We collect PI that you provide us in connection with your creation of an account. This Information includes your username, password, full name, email, and other information related to your use of the Platform. We may also have access to, and use of, PI that you provide to third parties that help us provide the services to you (i.e. payment processors). We primarily use PI to communicate with you about the Platform and our services, to help you manage your access to the Platform, to analyze activity on the Platform, to assess and address security issues, and to generally administer and improve the Platform. We may also use your PI to provide you with newsletters or our own marketing materials. We use anonymized Information or information in the aggregate for our business purposes and other than as specified in this Policy, we do not use aggregated information in a manner that allows identification of an individual user.

5.                Legal

We may use PI as required or permitted by law, including in response to service of legal process (court order, summons, subpoena, and the like). We may disclose PI to law enforcement or regulatory authorities as part of an investigation into activity at the Platform (such as a suspected breach) or in connection with your account. We shall use reasonable measures to limit disclosure and use of such PI. We may use PI in connection with the establishment or defense of legal claims.

6.                Security

Although no electronic method of transmission or storage is completely secure, we have implemented reasonable technical, physical and administrative safeguards designed to protect PI against loss and against unauthorized access, use, and disclosure. Account passwords are stored in encrypted form, but you are also responsible for the confidentiality of your account information and password and should act accordingly. If you lose your password, you must immediately notify us. We may retain PI as necessary for the purposes stated in Sections 4 or 5 or to otherwise meet legal requirements.

7.                Anonymous Information

We may collect AI regarding your use of the Platform, such as computer-related information, including the device or browser type you use, your Internet Protocol address, the website you came from or left to, and other information. We may send to your device a "cookie" or "pixel tag" that contains an identification number that is unique to the device you are using. You may decline, through your browser or machine settings, to provide such cookies or other information to us, although some of the Platform's features or services may not function properly as a result, and some services may not be available at all. We may use this AI to operate the Platform, to enhance the Platform, to understand how our Platform is used, to investigate and verify proper use of the Platform, and to monitor the security and integrity of the Platform.

8.                Third Party Agents — Access to and Use of the Information

We contract with third parties to assist us in administering the Platform and hosting the Information. This may require you or us to share Information in order to make the Platform available for your use. Such third parties agree with us to maintain your privacy at least with the level of protection set forth in this Policy.

9.                Third-Party Links and Information

Our Platform may contain links to websites or other information and materials provided by third parties, including, but not limited to, links to third-party content. We do not own or control such websites, content, or third parties and are not responsible for the information or services provided by those third parties. As such, we are not responsible for their privacy policies, terms of use or service, or the information collected at or by such third-party websites or services.

10.             Transfer of Information

We may transfer any information we have about you as an asset in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of a company reorganization or other change in company control.

11.             Information about Children

We do not knowingly collect PI from or about children under the age of 13.

12.             Your Access to PI

You may request access or updates to your PI or request a correction be made to an inaccuracy in your PI by contacting us as set out below or by using the functionality available on the Platform. For security purposes, we may request PI from you in connection with such request.

13.             Deleting and Retention of PI

You may request that we delete or deactivate your account or otherwise delete PI, and we shall attempt to accommodate such requests. However, we may retain and use PI for such periods of time as required by law or to continue to provide you with the Platform or any services related to the Platform.

14.             Third Party Tracking

Information is collected in connection with your use o the Platform and it may be shared with third parties. We may not recognize or respond to Do Not Track signals.

15.             Effective Date of Policy

The effective date of this Policy is September 28, 2018.

16.             Applicable Jurisdiction

This Policy is governed by the laws of the State of Michigan. We do not represent that it complies with privacy laws outside the United States. If your use of the Platform would be subject to the laws of a jurisdiction with which this Policy does not comply, you shall not use the Platform.

17.             Contact

Please contact us with any questions or comments you may have using the following contact information:

Megan Torrance, Inc.

311 Weiser Way

Chelsea, MI 48118

Attn: Privacy

Email:info@torrancelearning.com