Privacy Policy

In affect as of March 1, 2018.

 

Saint Paul Educacional Ltda. (hereinafter “LIT” or “We”) respects users’ right to privacy and will endeavor all efforts to protect this right in compliance with this policy (“Privacy Policy”).

 

This Privacy Policy describes the types of information that LIT may collect from users or that users may disclose to LIT as they log in to www.lit.com.br (“Website”), to mobile applications (“Applications”) or to other online services (hereinafter collectively referred to “Services” or “LIT Platform”), as well as LIT’s practices to collect, use, store, protect and disclose said information.

 

Users must read through this Privacy Policy carefully so as to get familiar with LIT’s treatment of user data. In case users do not agree with this Privacy Policy, they may also choose not to log in to LIT Platform. However, as they log in to or use LIT Platform, users automatically agree with this Privacy Policy. LIT does not disclose Users’ Personal Information without Users’ prior consent.

 

LIT regularly updates its practices and Privacy Policy. Users will be informed of updates and must abide by them so as to continue logging in and using LIT Platform. In case Users do not accept any update to the Privacy Policy, the rights of use and/or logging in to LIT Platform shall be suspended. Any Privacy Policy update shall become effective immediately after publication at LIT Platform. The continued use of Services after the updated version of the Privacy Policy has been published, whether said update has been notified or not, implies in Users’ acceptance and commitment to regularly checking for updates.

Should you require any clarification about any of the provisions of this Privacy Policy, please contact LIT.

 

Definitions

     

  1. Scope of this Privacy Policy

 

This Privacy Policy comprises User information collected both online and offline by LIT Platform, including data collected by LIT-contracted third party platforms. Users are responsible for the accuracy and validity of the personal information they supply. Inaccurate information may affect the use of LIT Platform, the content Users receive and LIT’s contact with Users.

 

  1. Information Collected by LIT

 

LIT collects a variety of information about Users of LIT Platform, including personal data such as name, address, e-mail address, telephone number (“Personal Information”) as well as information that will not directly allow User identification (“Non-Personal Information”). LIT also collects data about your Internet connection, the devise you use to connect to LIT Platform and log-in data.

 

Information is automatically collected by LIT and third party platforms as Users browse through LIT Platform, such as details about use, IP address and information collected by cookies and other tracking technologies.

 

– Information disclosed by Users

 

LIT collects information disclosed by Users when Users

     

  1. register into an account to log in and use LIT Platform;
  2. subscribe to LIT Platform, update and change information in their User Account;
  3. buy Services provided by LIT Platform, including information about payment mode;
  4. register into LIT Platform to receive information by e-mail about updates, activities and services;
  5. participate in Forums, surveys and promotions;
  6. report a problem at LIT Platform;
  7. post messages via e-mails, Forums, chats and other media and/or engage in activities and services;
  8. answer questions proposed by tests, activities and assessments;
  9. complete surveys and other research methods;  and
  10. log in or register at third party platforms using LIT Platform.

 

2.1 Information Collected via Automated Technologies

 

LIT may use automated technologies to collect information about devices, browsing actions and log in patterns while Users are interacting with LIT Platform, including

     

  1. details of visits to LIT Platform, comprising traffic and location data, logs and other exchanged data;
  2. LIT Platform pages that have been visited, including the sequence and time at which they were visited and which hyperlinks were clicked on;
  3. information about URLs that initiated the connection to LIT Platform;
  4. IP addresses, operational systems and browsing softwares used by Users;
  5. providers of applications and access used by Users;    and
  6. geographic location of Users’ point of connection.

 

The automated technologies used by LIT to collect information may include cookies (or browser cookies), instant cookies and/or web trackers. These technologies support identifying Users that browse through LIT Platform content and other websites to which Users connect, the length of time each User spends at each particular area of LIT Platform, as well as other specific functionalities that LIT may choose to use.

 

Browser cookies are small bits of data stored at Users’ hard disk. Most browsers supply set up instructions so as to reject cookies. In case Users reject cookies, a number of functionalities and conveniences supplied by LIT Platform may not work properly.

 

Flash cookies, also known as local shared objects, are resoures used by LIT Platform to collect and store information about Users’ preferences when browsing. They are not generated by the same set up of browser cookies. To access flash cookies, please go to your browser set up.

 

Web trackers, also known as web beacons, are small graphic images, also known as transparent gifs, pixel tags and pixel gifs, connected to LIT Servers that allow tracking the use of LIT Platform and related functionalities.

 

The automated data collection technologies used by LIT allows providing Users with a better targeted, customized and more efficient experience at LIT Platform. Cookies and web trackers are not used to store personal information.

     

  1. Use of Collected Information 

 

The information collected about or disclosed by Users, including personal information, is used to

     

  1. present LIT Platform and all its content to Users;
  2. customize, target and adapt Users’ learning;
  3. communicate with Users and respond to their queries, postings, etc.;
  4. check Users’ identify as well as their geographical location;
  5. supply information, products or services requested by Users to LIT;
  6. send communications about User Account, including notices about payment and subscription renewal;
  7. perform LIT’s rights and obligations pursuant to contracts entered into between Users and LIT ;
  8. notify Users about any update concerning LIT Platform, the Privacy Policy, Terms of Use or any other services supplied by LIT;
  9. allow Users to engage with LIT Platform interactive resources;
  10. develop higher quality Services by conducting statistic assessment of User characteristics and behaviors, measuring demographic data as well as any data of interest relevant to any area of LIT Platform;
  11. manage assessments, activities, projects and other assessments conducted at LIT Platform;
  12. monitor User performance and behavior during assessments and so as to verify compliance with applicable assessment rules and requirements at LIT Platform;
  13. conduct surveys and new business aimed at improving and customizing LIT Platform and other products and services supplied by LIT;
  14. track User participation, progress and task completion, as well as design User rankings as per the criteria set forth by LIT;
  15. share information regarding User performance in courses, tasks and other LIT Platform services with instructors, professors, assistants and other staff appointed by LIT to support the design, change and/or operation of LIT Platform;
  16. share User information with partnering universities and other LIT business partners;
  17. share information regarding User performance (grades, progress) in courses, tasks and other LIT Platform services with the User’s employer in the case of subsidized or sponsored subscriptions;
  18. conduct surveys/research related to education;
  19. assess User prior knowledge and psychological profile;
  20. map out courses and units of knowledge that Users have accessed;
  21. allow advanced User information processing and recovery, knowledge representation, automated reasoning and cognitive computing technologies by using algorithms, metrics and methodologies (“Automated Decisions”) and other own and third party tools, such as IBM’s Watson;
  22. share User personal information with government officials if summoned to do so by any legal instrument as well as to protect and defend LIT and its properties in law cases or as required by law;
  23. share User personal information whenever LIT deems it appropriate to investigate, prevent or take any action against confirmed or suspected illegal activity, as well as to protect and defend LIT and third party security and properties, as provided by the Terms of Use;
  24. respond to Users’ requests to keep data base records, to contract post-sales management services, to manage data and verify credit;
  25. assist the acquirer, assignee or other succeeding entity with respect to the sale, merger, restructuring of part or the whole of LIT’s equity, business or assets to which any user personal information might be relevant;    and
  26. any other purpose to which Users have granted consent.

 

LIT uses User personal information anonymously and separately to rigorously monitor the most frequently used LIT Platform resources, to analyze User and visitor browsing patterns and to determine what should be supplied and improved by LIT Platform. LIT shares this information with third parties to conduct statistical and market surveys.

 

LIT undertakes the obligation to store under secrecy, in safe and secure environments, all the records of User log in for six months.

 

  1. Forums and Chat Rooms

 

LIT may offer public forums and discussion groups (“Forums”), in which Users will share texts, images, voice recordings and other materials (“User-produced Content”). To engage in Forums, Users may be required to register personal information that may comprise or not pieces of information disclosed by or for Users within public media.  LIT may make chat rooms available to foster communication with other LIT Platform Users or contributors, and Users may just as well be required to supply personal information to access these functionalities.

 

User-produced Content disclosed at Forums, chat rooms and analog contexts are publicly available. Users may request that their produced content be altered or withdrawn from Forums, chat rooms and analog contexts. In such cases, all content-related comments and postings will also be removed from LIT Platform. That happening, LIT reserves the right to store under confidentiality all previous versions of said type of information in databases, including information that may or may not bear personal information.

 

Users must be aware that any User-produced Content bearing personal information that they disclose at Forums, chat rooms and analog contexts that may be accessed through LIT Platform Users may be collected and used by third parties and may result in unwanted messages sent by them. Users are solely responsible for all the activities they perform at the referred contexts and must be very careful towards disclosing any personal or confidential information at LIT Platform. Users should also read through the Terms of Use for additional information about how to use the Forums. For more information about withdrawing personal information from LIT Platform, please refer to Provision no. 9. 

 

LIT reserves the right to withdraw, without prior notice, any content that violates LIT’s or third parties’ copyrights, patents, registered marks, commercial secrets, advertising rights or any other intellectual property rights. Content withdrawal resulted from copyright violation may be performed upon request sent to LIT’s Violation Report Channel.

 

  1. Social Media Functionalities

 

LIT Platform also supplies interactive social media resources like the ‘Add’ button. These resources may collect Users’ IP Address, pages visited at LIT Platform, and set up cookies to allow proper functioning. Social media resources may be hosted by third parties or directly at LIT Platform. User interactions through said resources are also ruled by this Privacy Policy.

 

  1. Processing Payments

 

Payments must be made by credit card via a third party payment processor. To purchase the Service, Users must supply their credit card data to their credit card processor so that payments be duly processed.  LIT collects Users’ credit card information exclusively aiming to forward such information to Users’ credit card processor so the latter may regularly process payments. Such collected data is destroyed upon confirmation of receipt of said information.

 

  1. External Links

 

For Users’ convenience, LIT may show links to other websites that are managed by distinct companies (“Third Party Websites”). Third Party Websites operate independently from LIT Platform and may have their own privacy policies. Users should get acquainted with Third Party Websites policies if they access these websites. Since said websites are not comprehended by LIT Platform, LIT bears no liability for their content or privacy policy.  Users should get acquainted with Third Party Websites privacy policy and terms of use, as well as their practices to collect, use, store, protect and disclose user personal information. LIT will not disclose any user personal information to Third Party Websites without prior consent.  

 

Upon Users’ consent, LIT may import information from Third Party Websites (such as LinkedIn, Facebook and GooglePlus) and integrate such data to the User Account and/or social media interactive resources.

 

  1. Access, Update, Withdrawal and Retrieval of Personal Information 

 

Users may check if their personal information is correct and updated through their User Account at LIT Platform. Users may update, change or withdraw their personal information so that it is always correct. Users may also contact LIT to request that older versions of their personal information be stored as confidential in data basis, access records or other records that may or may not retrieve personal information.

 

At any time, Users may choose not to receive any more e-mails, notifications, promotion or marketing communication from LIT and one of our partners by explicitly expressing that in a reply email or by following the instructions supplied by such type of communication.

 

  1. Security

 

LIT undertakes all the relevant standard industry technical and management actions to prevent the loss of users’ personal data or illegal data processing, so as to keep data secure, such as, cryptography, firewalls, Secure Sockets Layer (SSL) as well as local physical measures that apply to data storage locations. Nevertheless, regardless of how effective these security technologies may be, no system may be said to be inscrutable. Therefore, LIT can not completely ensure the data base security or the security of users’ personal data. LIT waives any responsibility of any information entered by users. Users are responsible for protecting their log in information (user name, email and/or password). Users are kindly requested to immediately contact LIT when they believe their user account is at risk or has been broken into.

 

  1. Data Transfer

 

LIT may store or transfer Users’ personal information whether the latter are located in Brazil or anywhere else, including to countries that are not able to supply the same level of security to User personal information. LIT is committed to protecting Users’ personal information privacy, confidentiality and safety during data transfer. As they browse through or log in to LIT Platform, Users agree with and allow the transfer and processing of their personal information to servers located wherever Users are located as well as to foreign servers.

 

  1. Privacy Policy Update

 

LIT regularly updates its Privacy Policy. Users will be informed of any meaningful and significant update concerning the way LIT uses Users’ personal information by the email registered in their User Account as well as by notifications at LIT Platform. Users are responsible for ensuring their email address is up-to-date and active. Users are also responsible for regularly visiting this page of the Website to check for any Privacy Policy update. The latest Privacy Policy update is expressed at the top of this page.

 

  1. Minors Privacy Protection

 

LIT is concerned about minors’ security and does not intentionally collect, use or store any personal information of people under 18 (eighteen) years of age. As LIT Platform is not intended for this audience, minors are not allowed to register, log in or use LIT Platform or to provide LIT with any personal information. LIT will undertake the necessary measures to delete any personal information of minors.

 

  1. Contact Us

 

Should there remain any questions about this Privacy Policy, users should contact LIT.

 

Office Hours: Monday through Friday, from 10am to 5pm. 

 

E-mail: sac@lit.com.br