Privacy Policy

Effective date: 2022-03-16
1. Introduction
Welcome to Digitalatto Academy.
Digitalatto Academy (“us”, “we”, or “our”) operates (hereinafter
referred to as “Service”).
Our Privacy Policy governs your visit to, and explains how we
collect, safeguard and disclose information that results from your use of our Service.
We use your data to provide and improve Service. By using Service, you agree to the
collection and use of information in accordance with this policy. Unless otherwise defined in
this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our
Terms and Conditions.
2. What Information this Privacy Notice Covers
This Privacy Notice covers information we collect from you through our Site. Some of our
Site’s functionality can be used without revealing any Personal Data, but for features or
Services related to the Content Offerings, Personal Data is required. In order to access certain
features and benefits on our Site, you may need to submit, or we may collect, "Personal
Data" (i.e., information that can be used to identify you and which may also be referred to as
“personally identifiable information” or “personal information”). Personal Data can include
information such as your name, email address, IP address, and device identifier, among other
things. You are responsible for ensuring the accuracy of the Personal Data you submit to
Digitalatto Academy. Inaccurate information may affect your ability to use the Site, the
information you receive when using the Site, and our ability to contact you. For example,
your email address should be kept current because that is one of the primary manners in
which we communicate with you.
3. What You Agree to by Using Our Site
We consider that the legal bases for using your personal information as set out in this Privacy
Notice are as follows:
 our use of your personal information is necessary to perform our obligations under
any contract with you (for example, to comply with the Terms of Use of our Site
which you accept by browsing our website and/or to comply with our contract to
provide Services to you, your academic institution, your employer, or other
organization that may be providing you with access to our Services); or

 our use of your personal information is necessary for complying with our legal
obligations; or
 use of your personal information is necessary for our legitimate interests or the
legitimate interests of others. Our legitimate interests are to:
 run, grow and develop our business;
 operate our Site and provide our Services;
 select appropriately skilled and qualified suppliers;
 build relationships with partners and academic institutions;
 carry out research and statistical analysis;
 carry out marketing and business development; and
 for internal administrative and auditing purposes.
 consent, to send you certain communications or where you submit certain information
to us, or where required to rely upon consent by local law.
Which legal basis applies to a specific activity will depend on the type of personal
information used and the context in which it is being used.
If we rely on our (or another party’s) legitimate interests for using your personal information,
we will undertake a balancing test to ensure that our (or the other party’s) legitimate interests
are not outweighed by your interests or fundamental rights and freedoms which require
protection of the personal information.
We may process your personal information in some cases for marketing purposes on the basis
of your consent (which you may withdraw at any time as described below).
If we rely on your consent for us to use your personal information in a particular way, but
you later change your mind, you may withdraw your consent by visiting your profile page
and clicking the box to remove consent and we will stop doing so. If you withdraw your
consent, this may impact the ability for us to provide some of our Services to you.
4. What Information We Collect
We gather the following types of information about users through the Site:
1. Information relating to your use of our Site. When users come to our Site, we may
track, collect, and aggregate information indicating, among other things, which
pages of our Site were visited, the order in which they were visited, when they were
visited, and which hyperlinks were clicked. We also collect information from the
URLs from which you linked to our Site. Collecting such information may involve

logging the IP address, operating system, and browser software used by each user of
the Site. We may use and store information about your location if you give us
permission to do so (“Location Data”). We use this data to provide features of our
Service, to improve and customize our Service. You can enable or disable location
services when you use our Service at any time by way of your device settings. We
use cookies and similar tracking technologies to track the activity on our Service and
we hold certain information. Cookies are files with a small amount of data which
may include an anonymous unique identifier. Cookies are sent to your browser from
a website and stored on your device. Other tracking technologies are also used such
as beacons, tags and scripts to collect and track information and to improve and
analyze our Service.
2. Personal Data provided directly by you or via third parties. We collect Personal
Data that you provide to us when you register for an account, update or change
information for your account, purchase products or Services, complete a survey,
sign-up for email updates, participate in our public forums, send us email messages,
and/or participate in Content Offerings or other Services on our Site. We may use
the Personal Data that you provide to respond to your questions, provide you the
specific Content Offering and/or Services you select, send you updates about
Content Offerings or other Academy events, and send you email messages about Site
maintenance or updates.
 Account Registration. If you register for an account on our Site, you may be required
to provide us with certain Personal Data such as your name and email address. You
may also voluntarily provide us with additional Personal Data.
 Updates. Digitalatto Academy may offer you the ability to receive updates either via
email or by posting on portions of the Site only accessible to registered users. In
order to subscribe to these Services, you may be required to provide us with Personal
Data such as your name and email address.
 Forums. Digitalatto Academy may offer public forums from time to time (the
"Forums") where you can share comments and thoughts. In order to participate in the
Forums, you may be required to register with us and/or provide us with Personal
Data such as your name and email address. Please keep in mind that information you
post or make available in Forums will be publicly available. You should not include
any personal information or other information of a personal or sensitive nature,
whether relating to you or another person, in a Forum post. Please also reference our
Terms of Use and our Code of Conduct for additional information about proper use
of our Forums.
 Participation in Content Offerings. Digitalatto Academy offers users the opportunity
to participate in Content Offerings on or through the Site. If you desire to participate
in a Content Offering, you will be asked to provide us with certain information
necessary to conduct such a Content Offering. This information may include, among
other things, your name and email address.

If you participate in a Content Offering, we may collect certain user-generated content, such
as assignments you submit, peer-graded assignments, and peer grading feedback. We also
collect course data, such as responses to in-video quizzes, standalone quizzes, exams, and
surveys. You should not include any Personal Data or other information of a personal or
sensitive nature, whether relating to you or another person, on assignments, exams, or
surveys, except for information required to participate in or submit such assignments, exams,
or surveys.
 Identity Verification. Digitalatto Academy may offer you the ability to verify your
identity for select Services. In order to enroll for these Services, you may be required
to provide us or our third-party identity verification vendor with Personal Data such
as your name, address, date of birth, a headshot taken using a webcam, and a photo
identification document. Additionally, if you apply for financial aid in connection
with these Services, you may be required to provide information regarding your
 Communications with Digitalatto Academy. We may receive Personal Data when you
send us an email message or otherwise contact us.
 Third Party Sites. We may receive Personal Data when you access or log-in to a third
party site, e.g., Facebook, from our Sites. This may include the text and/or images of
your Personal Data available from the third party site.
 Surveys. We may receive Personal Data when you provide information in response to
a survey operated by us or a Content Provider.
 Partner sites. Partner sites providing Content Offering-related tools and services to
Digitalatto Academy users may collect nonfinancial individual-level user data
regarding the individual’s use of that partner site while the partner sites provide
those services to Digitalatto Academy. The partner sites may share that data with
Digitalatto Academy for the purpose of improving our Services, the partner site’s
services, and the individual’s education experience. This data includes information
such as the amount of time spent on the partner site and pages viewed.
 Third Party Payment Processing. Digitalatto Academy provides you with the ability to
pay for Content Offerings and other Services using a credit card or other methods
through a third party payment processing service provider. Please note that our
service provider – not Digitalatto Academy – collects and processes your financial
5. How We Use the Information
1. Information relating to your use of our Site. We use information relating to your
use of the Site to build higher quality, more useful Services by performing statistical
analyses of the collective characteristics and behavior of our users, and by measuring
demographics and interests regarding specific areas of our Site. We may also use this
information to ensure the security of our Services and the Site.
2. Personally Identifiable Information provided directly by you or via third
parties. Except as set forth in this Privacy Notice or as specifically agreed to by you,
Digitalatto Academy will not disclose any of your Personal Data. In addition to the

other uses set forth in this Privacy Notice, we may disclose and otherwise use
Personal Data as described below.
 Providing the Site and our Services. We use Personal Data which you provide to us in
order to allow you to access and use the Site and in order to provide any information,
products, or Services that you request from us.
 Technical support and security. We may use Personal Data to provide technical
support to you, where required, and to ensure the security of our Services and the
 Updates. We use Personal Data collected when you sign-up for our various email or
update services to send you the messages in connection with the Site or Content
Offerings. We may also archive this information and/or use it for future
communications with you, where we are legally entitled to do so.
 Forums. You should not post any personally identifiable information or other
information of a personal or sensitive nature, whether relating to you or another
person, within a Forum post. If you choose to post personally identifiable
information, such personally identifiable information may be collected during your
use of the Forums. We may publish this information via extensions of our platform
that use third-party services, like mobile applications. We reserve the right to reuse
Forum posts that contain personally identifiable information in future versions of the
Content Offerings, and to enhance future Content Offerings. We may archive this
information and/or use it for future communications with you and/or your
designee(s), and/or provide it to the Content Provider, business partners, or the
instructor(s) associated with the courses you have taken. We may also use or publish
posts submitted on the Forums without using personally identifiable information.
 Participation in Content Offerings. We use the Personal Data that we collect from you
when you participate in a Content Offering through the Site for processing purposes,
including but not limited to tracking attendance, progress, and completion of the
Content Offerings. We may also share your Personal Data and your performance in a
given Content Offering with the instructor or instructors who taught it, with teaching
assistants or other individuals designated by the instructor or instructors to assist
with the creation, modification, or operation of the Content Offering, and with the
Content Provider(s) with which they are affiliated. We may also use the information
generated when taking a Content Offering or using the Services for predictive
analysis of your performance in the Content Offerings. Also, we may archive this

information and/or use it for future communications with you, where we are legally
entitled to do so.
 Identity Verification. For Services that require identity verification, we may use the
Personal Data that we collect for verifying your identity, and for authenticating that
submissions made on the Site were made by you. This service may be provided
through a third-party identity verification vendor. Your photo identification
document will be deleted after successful verification of your profile information.
 Communications with or from Digitalatto Academy. When you send us an email
message or otherwise contact us, we may use the information provided by you to
respond to your communication and/or as described in this Privacy Notice. We may
also archive this information and/or use it for future communications with you where
we are legally entitled to do so. Where we send you emails, we may track the way
that you interact with these emails (such as when you open an email or click on a
link inside an email). We use this information for the purposes of optimizing and
better tailoring our communications to you.
 Communications with Digitalatto Academy Business Partners. We may share your
Personal Data with Content Providers and other business partners of Digitalatto
Academy so that Content Providers and other business partners may share
information about their products and services that may be of interest to you where
they are legally entitled to do so.
 Research. We may share general course data (including quiz or assignment
submissions, grades, and forum discussions), information about your activity on our
Site, and demographic data from surveys operated by us with our Content Providers
and other business partners so that our Content Providers and other business partners
may use the data for research related to online education.
 Disclosure to Digitalatto Academy Operations and Maintenance Contractors. We use
various service providers, vendors, and contractors (collectively, "Contractors") to
assist us in providing our Services to you. Our Contractors may have limited access
to your Personal Data in the course of providing their products or services to us, so
that we in turn can provide our Services to you. These Contractors may include
vendors and suppliers that provide us with technology, services, and/or content
related to the operation and maintenance of the Site or the Content Offerings. Access
to your Personal Data by these Contractors is limited to the information reasonably
necessary for the Contractor to perform its limited function for us.

 Government Authorities; Legal Rights and Actions. Digitalatto Academy may share
your Personal Data with various government authorities in response to subpoenas,
court orders, or other legal processes; to establish or exercise our legal rights or to
protect our property; to defend against legal claims; or as otherwise required by law.
In such cases we reserve the right to raise or waive any legal objection or right
available to us. We also may share your Personal Data when we believe it is
appropriate to investigate, prevent, or take action regarding illegal or suspected
illegal activities; to protect and defend the rights, property, or safety of Digitalatto
Academy, the Site, our users, customers, or others; and in connection with our
Terms of Use and other agreements.
 Disclosure to Acquirers. Digitalatto Academy may disclose and/or transfer your
Personal Data to an acquirer, assignee or other successor entity in connection with a
sale, merger, or reorganization of all or substantially all of the equity, business, or
assets of Digitalatto Academy to which your Personal Data relates.
 e-Readers. If we receive any Personal Data related to the extent to which you use
designated e-Readers or other devices to access Digitalatto Academy materials, we
may archive it, and use it for research, business, or other purposes.
6. External Links
For your convenience we may provide links to sites operated by organizations other than
Digitalatto Academy ("Third Party Sites") that we believe may be of interest to you. We do
not disclose your Personal Data to these Third Party Sites unless we have a lawful basis on
which to do so. We do not endorse and are not responsible for the privacy practices of these
Third Party Sites. If you choose to click on a link to one of these Third Party Sites, you
should review the privacy policy posted on the other site to understand how that Third Party
Site collects and uses your Personal Data.
7. Retention of Personally Identifiable Information
We will retain your Personal Data only for as long as is necessary for the purposes set out in
this Privacy Policy. We will retain and use your Personal Data to the extent necessary to
comply with our legal obligations (for example, if we are required to retain your data to
comply with applicable laws), resolve disputes, and enforce our legal agreements and
policies. We will also retain Usage Data for internal analysis purposes. Usage Data is
generally retained for a shorter period, except when this data is used to strengthen the security
or to improve the functionality of our Service, or we are legally obligated to retain this data
for longer time periods.

8. Confidentiality & Security of Personally Identifiable Information
We will use industry standard physical, technical, and administrative security measures to
keep your Personal Data confidential and secure, and will not share it with third parties,
except as otherwise provided in this Privacy Notice, or unless such disclosure is necessary in
special cases, such as a physical threat to you or others, as permitted by applicable law.
Because the Internet is not a 100% secure environment, we cannot guarantee the security of
Personal Data, and there is some risk that an unauthorized third party may find a way to
circumvent our security systems or that transmission of your information over the Internet
will be intercepted. It is your responsibility to protect the security of your login information.
Please note that e-mail communications are typically not encrypted and should not be
considered secure.
9. Updating or Deleting Your Personal Data
You have certain rights in relation to your Personal Data. You can access your Personal Data
and confirm that it remains correct and up-to-date, choose whether or not you wish to receive
material from us or some of our partners, and request that we delete or provide you with a
copy of your personal data by logging into the Site, selecting ‘Settings’ from the dropdown in
the top right, and scrolling down to find the appropriate option. The ability to delete an
account may be disabled for some users, particularly those who are enrolled in for-credit
offerings such as degrees, MasterTrack certificate programs, and other similar offerings.
If you would like further information in relation to your rights or would like to exercise any
of them, you may also contact us via [email protected]. If you reside or are
located in the EEA, United Kingdom, Switzerland, or other region that offers similar
protections, you have the right to request that we:
 provide access to any Personal Data we hold about you;
 prevent the processing of your Personal Data for direct-marketing purposes;
 update any Personal Data which is out of date or incorrect;
 delete any Personal Data which we are holding about you;
 restrict the way that we process your Personal Data;
 provide your Personal Data to a third party provider of services; or
 provide you with a copy of any Personal Data which we hold about you.

We try to answer every request promptly where possible, and provide our response within the
time period stated by applicable law. Keep in mind, however, that when deleting your
Personal Data there may be residual information that will remain within our databases, access
logs, and other records, which may or may not contain your Personal Data. Please also note
that certain Personal Data may be exempt from such requests in certain circumstances, which
may include if we need to retain your Personal Data to comply with a legal obligation. When
you email us with a request, we may ask that you provide us with information necessary to
confirm your identity.
10. California Privacy Rights
Shine the Light Under California’s "Shine the Light" law, California residents who provide
personal information in obtaining products or services for personal, family, or household use
are entitled to request and obtain from us, once a calendar year, information about the
customer information we shared, if any, with other businesses for their own direct marketing
uses. If applicable, this information would include the categories of customer information and
the names and addresses of those businesses with which we shared customer information for
the immediately prior calendar year (e.g. requests made in 2018 will receive information
regarding 2017 sharing activities).
To obtain this information, please send an email message
to [email protected] with "Request for California Privacy Information" on the
subject line and in the body of your message. We will provide the requested information to
you at your email address in response. Please be aware that not all information sharing is
covered by the "Shine the Light" requirements and only information on covered sharing will
be included in our response.
11. California Consumer Privacy Act
Under the California Consumer Privacy Act (“CCPA”), California residents have the right to
know what personal information about them is collected, request deletion of their personal
data, opt-out of the sale of their personal data, and not be discriminated against if they choose
to exercise any of these rights. Digitalatto Academy does not sell any of the data we collect
about you. If you’d like to exercise any of the other rights afforded to you, contact us
at [email protected].
For more information about how we process the personal information of California residents
and the rights that California residents have under the CCPA, please review our full CCPA
Notice here.

12. International Privacy Practices
Our Sites are primarily operated and managed on servers located and operated within the
United States. In order to provide our products and Services to you, you may be sending your
Personal Data outside of the country where you reside or are located, including to the United
States. Accordingly, if you reside or are located outside of the United States, your Personal
Data may be transferred outside of the country where you reside or are located, including to
countries that may not or do not provide the same level of protection for your Personal Data.
We are committed to protecting the privacy and confidentiality of Personal Data when it is
transferred. If you reside or are located within the EEA, United Kingdom, Switzerland, or
other region that offers similar protections, and such transfers occur, we take appropriate
steps to provide the same level of protection for the processing carried out in any such
countries as you would have within the EEA or other regions to the extent feasible under
applicable law. We participate in and commit to adhering to the EU-U.S. and Swiss-U.S.
Privacy Shield Frameworks when transferring data from the EEA or Switzerland to the
United States. Please see our Privacy Shield Notice below for further information.
13. Children’s Privacy
Our Services are not intended for use by children under the age of 18 (“Child” or
We do not knowingly collect personally identifiable information from Children under 18. If
you become aware that a Child has provided us with Personal Data, please contact us. If we
become aware that we have collected Personal Data from Children without verification of
parental consent, we take steps to remove that information from our servers.
14. Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by
posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Service, prior to the change
becoming effective and update “effective date” at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this
Privacy Policy are effective when they are posted on this page.
15. Contact Us
If you have any questions about this Privacy Policy, please contact us by email:
[email protected].