Flare Learning Privacy Policy

By using any Neovation® Services, you are agreeing to the terms in this Privacy Policy. Be sure to occasionally check back for updates.

This Privacy Policy is intended to help you better understand how we collect, use, and store your Personal Information—whether you are a Subscriber to a Neovation product such as Neovation or SmarterU, or use any Neovation Website such as FlareLearning (together, the “Service”), or an end-user that uses our technology, or whether you’re simply visiting this Website.

By using the Service, or visiting this Website, directly or through an individual or organization using the Service, you are agreeing to the terms of this Privacy Policy and, as applicable, the product’s Terms of Use or Master Subscription Agreement.

We may update this Privacy Policy from time to time in order to reflect changes to our privacy practices or for other operational, legal, or regulatory reasons. If we make material changes to this Privacy Policy, we will give you notice of such changes by posting the revised policy on this Website, and where appropriate, by other means. By continuing to use this Website or the Service after these changes are posted, you agree to the revised policy.

Note to Residents of the European Union: In order to comply with the requirements of applicable privacy laws, this Privacy Policy outlines the legal basis on which Neovation processes your personal data (also referred to as Personal Information herein). Please see the relevant sections below for additional information as required by applicable laws.

We believe your business is no one else’s. Your privacy is important to you and to us. So we’ll protect the information you share with us. To protect your privacy, Neovation follows key principles in accordance with worldwide practices for customer privacy and data protection.

1. We won’t sell or give away your name, mail address, phone number, email address, or any other information to anyone.
2. We’ll use security measures to protect your information from unauthorized users.

NOTICE

We will ask you when we need information that personally identifies you (Personal Information) or allows us to contact you. We use your Personal Information for four primary purposes:

1. To make the Website easier for you to use by not having to enter information more than once.
2. To help you quickly find software, services, or information.
3. To help us provide the Service and create content most relevant to you.
4. To communicate with you and alert you to product upgrades, special offers, updated information, and other new services from Neovation (in accordance with Canada’s Anti-Spam Legislation, as discussed below).

The type of information that Neovation may collect from you includes, for example, your name, email address, address, phone number, and other information you choose to provide. Financial information is also collected by Neovation when you pay for the right to use Neovation’s products and the Service.

Neovation may collect Personal Information for other purposes where it has a legal duty or right to do so or where Neovation has a good faith belief that it is necessary to protect the property or rights of Neovation.

Neovation does not collect your Personal Information for any other purposes, unless it has your consent.

COLLECTION

Neovation only collects Personal Information about an individual with the individual’s knowledge and consent. Generally, this means that Neovation collects personal information directly from the individual to whom it relates, whether via the Website, e-mail, telephone, or in person. Occasionally, Neovation may collect personal information from third party sources, but only with the knowledge and consent of the individual or where otherwise authorized by law.

Visitors to the Website should also be aware that anonymous technical information may be collected by Neovation as a result of a visit to the Website. For example, this information may include your IP address, browser type, operating system, domain name, access times and referring website addresses. Neovation uses this anonymous technical information for purposes such as diagnosing problems with Neovation’s servers, improving the operation and content of the Website and compiling aggregate and statistical information.

Neovation will not attempt to link or match such anonymous technical information with any personally-identifiable information unless Neovation has your consent, Neovation (or its service providers) have detected or reasonably suspect any unlawful use of the Service or a security breach, or Neovation has a legal duty or right to do so.

Neovation may use “cookies” on the Website. “Cookies” are small text files placed on computers that can collect and store a variety of information. Permanent cookies are stored indefinitely on a user’s hard drive unless manually deleted, while temporary cookies are automatically deleted from the user’s browser upon logging out of a website. Web browsers typically allow users to disable permanent and/or temporary cookies. For more general information on cookies see the Wikipedia article on HTTP Cookies.

The Cookies We Set

We set and use cookies to track your interactions with us:

• If you create an account with us, then we will use cookies for the management of the signup process and general administration. These cookies will usually be deleted when you log out. In some cases, they may remain afterward to remember your site preferences when logged out.
• We use cookies when you are logged in so that we can remember this fact. This prevents you from having to log in every single time you visit a new page. These cookies are typically removed or cleared when you log out to ensure that you can only access restricted features and areas when logged in.
• Our Website offers variable content as well as newsletter or email subscription services. Cookies may be used to remember if you are already registered and whether to show certain notifications which might only be valid to subscribed/unsubscribed users.
• From time to time we offer user surveys and questionnaires to provide you with interesting insights, helpful tools, or to understand our user base more accurately. These surveys may use cookies to remember who has already taken part in a survey or to provide you with accurate results after you change pages.
• When you submit data through a form such as those found on contact pages or comment forms cookies may be set to remember your user details for future correspondence.

USE AND DISCLOSURE

Neovation only uses or discloses Personal Information as reasonably required to facilitate the primary purposes described above.

In some cases, Neovation may share personal information with third party service providers performing functions on Neovation’s behalf, including, for example, vendors that provide information technology services or provide analytics or assessment services.

Neovation will disclose your Personal Information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Neovation or the Website; (b) protect and defend the rights or property of Neovation and its Website, and, (c) act in urgent circumstances to protect the personal safety of users of the Service or the Website, or the public.

Neovation does not rent, sell or trade customer lists or other Personal Information.

CONSENT

You provide your consent to the collection, use, and disclosure of your Personal Information by Neovation when you provide your information to Neovation on the Website or when using the Service.

You can deny or withdraw your consent to the collection, use and disclosure of your Personal Information at any time upon reasonable notice, subject to any legal or contractual requirements. If your consent is denied or withdrawn or you choose not to register or provide Personal Information, you can still use most of our Website. However, you will not be able to access areas that require registration such as the Service.

If you decide to register, you will be able to select the kinds of information you want to receive from us by subscribing to various services, like our electronic newsletters. Neovation may use Personal Information to inform you of current and/or new products or services or other developments that Neovation believe will be of interest to you in accordance with applicable laws including Canada’s Anti-Spam Legislation. Such communications may be made by way of telephone, text message, direct messaging, e-mail, fax or regular mail. Individuals provide their consent to Neovation contacting them in this manner when they use the Service.

If you do not want us to communicate with you about other offers regarding Neovation products, programs, events, or services by email, postal mail, or telephone, you may unsubscribe using the supplied instructions.

SECURITY AND LOCATION

Neovation has taken strong measures to protect the security of your Personal Information and to ensure that your choices for its intended use are honored. We take precautions to protect your data from loss, misuse, unauthorized access or disclosure, alteration, or destruction. These measures include reasonable policies, procedures and safeguards (including physical, technological and organizational measures) designed to protect the security of Personal Information under our control.

Your Personal Information is never shared outside the company without your permission, except under conditions explained above. Inside the company, data is stored in password-controlled servers with limited access.

The protection of Personal Information is of paramount concern to Neovation and Neovation is prepared to take appropriate and timely steps in the event of any incidents involving Personal Information in accordance with applicable privacy laws.

ACCESS

Neovation will provide you with access to your Personal Information that Neovation holds about you in accordance with applicable laws. Neovation reserves the right to require that any request for access to Personal Information be made in writing. Generally, there is no cost for such access. However, Neovation reserves the right to charge such costs on a case by case basis in accordance with applicable laws. You will be notified in advance if charges apply.

Neovation will correct or amend the Personal Information in its files where it can be shown that the information is incorrect or incomplete.

CONTACT

We retain personal information only as long as is reasonable to fulfill the purposes for which the information was collected, or as otherwise required for legal or business purposes. We will continue to store information such as website visits, in order to improve the Service.

RETENTION

We retain personal information only as long as is reasonable to fulfill the purposes for which the information was collected, or as otherwise required for legal or business purposes.  For greater certainty, Neovation does not retain any client data uploaded to an account through use of Neovation.

We will continue to store information such as website visits, in order to improve the Service.

ADDITIONAL INFORMATION FOR RESIDENTS OF THE EUROPEAN UNION

The following information is provided for European users who may access the Website or use the Service.

The European General Data Protection Regulation (GDPR) sets out obligations and rights with respect to the personal data of residents of the European Union. Neovation is committed to ensuring that it complies with the requirements of the GDPR. As such, this section outlines additional information relevant to residents of the European Union only. Please see the remainder of Neovation’s Privacy Policy for more information on our privacy practices.

Your Rights relating to your Personal Data

Subject to some exceptions, the GDPR provides you with the following rights:

1. Right of access: You have the right to information about whether and why we process your personal data and related information (for example, what personal data we are processing).
2. Right of access: You have the right to information about whether and why we process your personal data and related information (for example, what personal data we are processing).
3. Right to erasure: You have the right to ask us to delete personal data that we hold about you.
4. Right to restrict or object to processing: You have the right to ask us to limit or stop our processing of your personal data in certain cases (for example, if the personal data we are processing about you is inaccurate or is for direct marketing purposes).
5. Right to data portability: You have the right to ask us for a copy of personal data we hold about you and to transfer such data to another entity.
6. Right to complain: We encourage you to contact us at the contact information above if you have any questions or concerns with our personal data practices. However, you also have the right to complain to regulatory authorities in your jurisdiction. Please contact us at the contact information above if you need information about the appropriate authority.

You may exercise these rights or find out more about these rights by contacting Neovation.

Retention and Storage of Personal Data

Neovation is based in Canada and processes personal data in Canada. The European Commission recognizes Canada as providing an adequate level of protection for personal data.

Neovation’s service providers may process your Personal Information outside of Canada (please see above). When your information is processed outside of the European Union, it may be subject to the laws of and be accessible by legal authorities in such other jurisdictions. Neovation has taken appropriate technical, organizational, and legal steps to secure this information.