2HR Learning Privacy Policy

2HR Learning (collectively, “2HR Learning“, “we“, or “us“) respects your privacy. This 2HR Learning Privacy Policy (“Privacy Policy”) describes the ways we collect information from and about you and/or your children (collectively, hereinafter referred to as “you”/ “your”), what we do with the information, and your privacy rights. By accessing our website, or using any applications, mobile apps or other technological products or services that are made available to you in connection with 2HR Learning (the “2HR Learning Technology”), you agree to the terms of this Privacy Policy in addition to any other agreements we might have with you. This Privacy Policy applies to personal data processed by 2HR Learning in conjunction with use of the 2HR Learning Technology, and discloses information concerning data collection, usage and sharing about you as a user of the 2HR Learning Technology. This Privacy Policy specifically describes such activities about a student or child in Section 12 and has additional information about parents in Section 13, including rights of parents with respect to children under the age of 13.

This Privacy Policy applies to personal data processed by 2HR Learning in conjunction with use of the 2HR Learning Technology, and discloses information concerning data collection, usage and sharing about you as a user of the 2HR Learning Technology. This Privacy Policy specifically describes such activities about a student or child in Section 12 and has additional information about parents in Section 13, including rights of parents with respect to children under the age of 13.

IMPORTANT:

The educational success of the 2HR Learning Technology relies on extensive data collection and analysis in order to assist with achieving the results desired from the 2HR Learning Technology. Similar to the use of data collection and analysis in professional sports to improve and gain a performance edge, we may use every available lawful means in order to improve a student’s performance. The data collection and processing described in this Privacy Policy and utilized as part of the 2HR Learning Technology are integral to the experience and a necessary part of the overall program. Some specific examples of possible data collection and analysis:

1. Test Scores: Academic and cognitive test scores prior to and during the program are collected, tracked and analyzed.

2. Recordings: All group, 1:1 and online meeting sessions may be recorded with audio and/or video, including interactions on Zoom or any similar system.

3. Activity Tracking: Screenshots, including browser, screen or computer activity, may be taken while a student is working. Keyboard and mouse activity may also be tracked. Webcams, computer microphones and online meeting tools may be used to record the student as part of the 2HR Learning Technology. In the pro sports analogy, this is game film which allows analysis, instruction and improvement of both learning and instruction.

4. Productivity Gamification: Productivity may be tracked in order to display a leaderboard to users, or provide rewards, and the purchase or other history related to the redemption of those rewards may be tracked and analyzed.

5. Biometrics: Biometric data, information and identifiers may be collected to analyze and improve learning, or as part of assessments, evaluation and testing.

6. Marketing: You may choose to take part in marketing videos or photos for the 2HR Learning website, social media and other online and offline properties or media describing their interactions with 2HR Learning. You may also appear in videos or photos if you are participating in group activities. You expressly give permission for 2HR Learning and any such media to use your image or likeness in any digital media format (e.g., photo, video, website, email and web-related publications) or associated format (photo or screenshot for a physical newsletter referencing the online media) in connection with the purposes described above, without payment, including the right to digitally alter the image, and release any and all copyright ownership or claims. For clarity, this release and permission also extends to your child.

We intend to proceed with additional data collection in the future, or in specific student cases, which may involve the use of additional software, hardware, or mobile phone applications/usage.

We may provide certain options to opt-out of data collection that may be sensitive, and may provide additional or different options to opt-out of data collection in the future. Nevertheless, if you exercise an option to opt-out of particular data collection on your student’s computer, your student may still be subject to recording on another device or technology where the parent has not exercised the right to opt-out.

Our intent is to utilize the 2HR Learning Technology now and in future iterations to leverage data and technology to its fullest in order to put your student in the position to learn, which may include automated analysis and actions as a result of the processing of this data. If you do not wish to put data and technology to work in this manner, please explore alternative options for your education.

1. Our Collection of Parent, Student and Your Information:

Personal Data. The information we collect may include your personal data, such as your name, contact information, IP addresses, information concerning your education and usage of the 2HR Learning Technology, and other data that may identify you.

We collect personal data about you at several different points, including but not limited to the following:

1. In connection with a business or educational opportunity or meeting;

2. When we engage in educational instruction or correspond with you;

3. When you use the 2HR Learning Technology, including but not limited to when you register as an user of 2HR Learning Technology and an account is created for you;

4. when you schedule a meeting with us in connection with a student, you may need to provide your name and your child’s name, and your email address and phone number;

5. when you enroll in any newsletter or other periodic communication;

6. when you enroll in any newsletter or other periodic communication;

7. when you contact us for help;

8. when the 2HR Learning Technology captures analytics data or sends error reports;

9. when you choose to provide materials or information as part of the 2HR Learning Technology; and

10. as described in Section 12 (Children’s Privacy) and Section 13 (Parental Rights).

2. Information Collected Automatically or From Others

Automatic Data Collection. We may collect certain information automatically when you use the 2HR Learning Technology.  This information may include your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after using the 2HR Learning Technology, information about the links you click, and other information about how you use the 2HR Learning Technology.  Information we collect may be associated with accounts and other devices. 2HR Learning Technology may collect precise geolocation information in accordance with applicable law.

In addition, we may automatically collect data regarding your use of 2HR Learning Technology, such as the types of content you interact with and the frequency and duration of your activities.  Unless contrary to applicable law or contractual agreement, we may combine your information with information that other people provide when they use 2HR Learning Technology.

Cookies, Pixel Tags/ Web Beacons, Analytics Information, and other technologies.  We, as well as third parties that provide content, or other functionality on the 2HR Learning Technology, may use cookies, pixel tags, local storage, and other technologies (“Analytics Systems”) to automatically collect information through the 2HR Learning Technology.  Analytics Systems are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us and our partners to record certain pieces of information whenever you visit or interact with 2HR Learning Technology.

1. Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences.  Most browsers allow you to block and delete cookies.  However, if you do that, the 2HR Learning Technology may not work properly.

2. Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the 2HR Learning Technology that collects information about users’ engagement on the 2HR Learning Technology.  The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular item.

Analytics. We may use analytics as part of the 2HR Learning Technology, including without limitation Google Analytics, a service for the analysis of technology usage that is provided by Google, Inc. Google Analytics and other analytics uses cookies to allow us to see how you use the 2HR Learning Technology, so we can improve your experience. Google’s ability to use and share information collected by Google Analytics about your visits to the site is restricted by the Google Analytics Terms of Use available at http://www.google.com/analytics/terms/us.html and the Google Privacy Policy available at http://www.google.com/policies/privacy/. You can prevent Google Analytics from recognizing you on return visits to the site by disabling cookies in your browser. If you prefer to not have data reported by Google Analytics, you can install the Google Analytics Opt-out Browser Add-on available at https://tools.google.com/dlpage/gaoptout For information about other analytics services used, please contact us using the contact information below.

Information from Other Sources. We may obtain information about you from other sources, including from our customers, partners or through third party services and organizations to supplement information provided by you.  For example, the 2HR Learning Technology may collect information about you from a 2HR Learning customer or third-party learning applications and compile that information as part of the 2HR Learning Technology. Additionally, if you access 2HR Learning Technology through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made public via your privacy settings. Information we collect through 2HR Learning Technology may include your name, your user identification number, your user name, location, gender, birth date, email, profile picture, and your contacts stored in that service.  This supplemental information allows us to, among other things, verify information that you have provided to us and to enhance our ability to provide you with appropriate information as part of your educationand 2HR Learning Technology.

Third Party Information You Submit. If you submit any personal data about another individual to us, you are responsible for making sure that you have the authority to do so and to allow us to use their personal data in accordance with this Privacy Policy.

Children’s Privacy and Parental Rights. As further described in Section 12 (Children’s Privacy) and Section 13 (Parental Rights) and above in the description of the importance of the 2HR Learning Technology.

2HR Learning may use information that we collect about you to:

A. Fulfill educational objectives, such as:

1. Delivering the educational services by way of the 2HR Learning Technology;

2. Managing our relationship with you and provide you with support and other assistance;

3. Communicating with you by email, postal mail, telephone or mobile devices about your education, 2HR Learning and the 2HR Learning Technology;

4. Undertaking activities to verify or maintain the quality or safety of 2HR Learning and the 2HR Learning Technology;

5. Managing 2HR Learning and the 2HR Learning Technology;

6. Allowing you to register for events or other opportunities.

B. Analyze and improve education and 2HR Learning Technology pursuant to our legitimate interest, such as:

1. Utilizing the information to improve your education;

2. Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;

3. Performing research and analysis about your use of, or interest in, 2HR Learning Technology or content offered by others, and short-term, transient use, such as contextual customization;

4. Undertaking research for educational and technological development and demonstration;

5. Improving, upgrading or enhancing 2HR Learning Technology or the applications, offerings and services of our service providers;

6. Verifying your identity and preventing fraud;

7. Debugging of the 2HR Learning Technology to identify and repair errors that impair existing intended functionality; and

8. Enforcing our terms and legitimate interests.

C. Provide you with additional content and educational opportunities, such as:

1. Developing and displaying content and educational materials tailored to you as part of the 2HR Learning Technology;

2. Auditing of 2HR Learning and the 2HR Learning Technology relating to interactions, transactions and other compliance activities; and

3. Performing functions you consent to or that are otherwise described to you at the time of collection.

D. As further described in Section 12 (Children’s Privacy), Section 13 (Parental Rights) and above in the description of the importance of the 2HR Learning Technology.

Use De-identified and Aggregated Information.  We may use personal data and other data about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access 2HR Learning Technology, or other analyses we create.

Share Content with Others.  2HR Learning Technology may offer various tools and functionalities to share with other users. 

3. Our Disclosure of Parent, Student and your Personal Data to Third Parties

We may share your personal data with third parties only in the ways that are described in this Privacy Policy.

1. Affiliates and Service Providers. We may provide your information to affiliated entities within our corporate group, as well as with vendors who perform functions on our behalf; such parties provide hosting and maintenance services, virtual infrastructure, payment processing, analysis and other services for us.

2. Independent Contractors. We may utilize independent contractors subject to confidentiality obligations as an alternative to employees.

3. Business Partners. We may share your data with any parent company, subsidiaries, joint ventures, and other entities under a common control or third-party acquirers;

4. Disclosure for Merger, Sale or Other Asset Transfer. We may allow a potential acquirer or merger partner to review our information, although we would restrict their use and disclosure of this data during the diligence phase;

5. Disclosure to Protect Us or Others. As required by law enforcement, government officials, or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to 2HR Learning; or when we believe, in our sole discretion, that the disclosure of personal data is necessary to prevent physical harm or financial loss; to report suspected illegal activity or to investigate violations of our agreements or 2HR Learning policies; to enforce our terms and conditions, to protect the security or integrity of our products and services.

6. Based on Consent. When you give us permission to do so.

7. Children’s Privacy and Parental Rights. As further described in Section 12 (Children’s Privacy) and Section 13 (Parental Rights) and above in the description of the importance of the 2HR Learning Technology.

Please note that these third parties may be in other countries from you.

Potential for Other Users to Contact You. To the extent that a given application supports personal messaging functionality or email between and among users of the 2HR Learning Technology, you may receive personal messages from other users.  You may be able to disable this functionality by using the unsubscribe and other disabling instructions in the given application.

Prohibited Disclosures. We will not sell personally identifiable information of children or parents to third parties. Furthermore, we will not disclose any information for behavioral targeting of our students.

4. Our Security Measures to Protect your Personal Data

2HR Learning uses industry-standard technologies when transferring and receiving data exchanged between 2HR Learning and other companies to help ensure its security. The 2HR Learning Technology has security measures in place to help protect information under our control from the risk of accidental or unlawful destruction or accidental loss, alteration or unauthorized disclosure or access. However, “perfect security” does not exist on the Internet.  Also, if the 2HR Learning Technology contains links to other sites, 2HR Learning is not responsible for the security practices or the content of such sites.

5. Our Use of Automatic Collection, Links and Other Technologies

1. Automatic Collection Technologies. We, as well as third parties on the 2HR Learning Technology, may use Analytics Systems to automatically collect information through the 2HR Learning Technology. Our uses of these Analytics Systems fall into the following general categories:

   • Operationally Necessary. This includes Analytics Systems that may allow for the identification of irregular site behavior, prevent fraudulent activity and improve security or that are essential to allow you to make use of our functionality;

   • Performance Related. We may use Analytics Systems to assess the performance of 2HR Learning Technology, including as part of our analytic practices to help us understand how students use the 2HR Learning Technology;

   • Functionality Related. We may use options or other systems that allow us to offer you enhanced functionality when accessing or using 2HR Learning Technology. This may include identifying you when you sign into 2HR Learning Technology or keeping track of your specified preferences, interests, or past items viewed;

   • Targeting Related. We may use first party or third-party Analytics Systems to deliver content, including content determined relevant to you, on 2HR Learning Technology.

2. Website Links. We may create links to other websites. Additionally, many other sites that are not associated with or authorized by 2HR Learning may have links leading to our site. 2HR Learning cannot control the material in connection with these links and we are not responsible for any content appearing on these sites. You are subject to the privacy practices of that third party. We encourage you to ask questions before you disclose any personal data to others.

3. App Links. 2HR Learning Technology may provide you with a link to other, third-party sites and applications. Such third-party sites will have their own data collection practices and policies. Please review the privacy policy for such sites and exercise caution in providing information that personally identifies you. We have no responsibility, access, or control over the data collection practices and policies of such third-party sites and applications. You will use such sites and applications at your own risk and outside of the scope of this Privacy Policy. The provision of such applications is done on an “As Is” basis, with no endorsements or representations.

4. Cross-Device Tracking. Your browsing activity may be tracked across different websites and different devices or apps. For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your laptop. To do this, our technology partners may share data, such as your browsing patterns, geo-location, and device identifiers, and will match the information of the browser and devices that appear to be used by the same person.

5. Notice Regarding Third Party Websites, Social Media Platforms, and Software Development Kits. 2HR Learning Technology may use third parties to present or serve content and technology, software, or services. These third parties may gather information concerning the content delivered, your use of the 2HR Learning Technology, and other information in connection with their services and your usage.

We may use third party software, APIs and software development kits (“SDKs”) as part of the functionality of 2HR Learning Technology. The software, APIs and SDKs may allow third parties including analytics and advertising partners (to the extent disclosed) to collect your personal data for various purposes including to provide analytics services and content that is more relevant to you. For more information about our use of third-party software, APIs and SDKs, please contact us as set forth below.

2HR Learning Technology may include publicly accessible or private websites, blogs, forums, social media pages, and private messaging features. To the extent permitted by applicable law, by using such 2HR Learning Technology, you assume the risk that the personal data provided by you may be viewed and used by third parties for any number of purposes. In addition, social media buttons such as Twitter and LinkedIn (that might include widgets such as the “share this” button or other interactive mini-programs) may be utilized as part of the 2HR Learning Technology. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a third party or hosted directly on our site. Your interactions with these features apart from the 2HR Learning Technology are governed by the privacy policy of the company providing it.

This Privacy Policy does not cover certain uses of information that such third parties may have collected from you or the methods used by the third parties to collect that information. To the extent permitted by applicable law, we do not endorse, screen or approve and are not responsible for the privacy practices or content of such other websites or applications.  Visiting these other websites or applications is at your own risk.

6. Data Retention

Information will be maintained for the period required to achieve the purpose for which the information was collected. We will follow a data retention schedule which may retain some permanent academic school records indefinitely and deidentify or destroy other records according to a retention schedule that ranges from graduation / disenrollment to 4-5 years later. Information that is transitory and not needed to fulfill a long term purpose will be deidentified or destroyed sooner.

7. International Transfers of your Personal Data

Information about you may be stored and processed in the United States, European Economic Area, or any other country in which our agents, contractors or service providers maintain facilities, and by accessing our websites and using our mobile apps, software and 2HR Learning Technology, you consent to the transfer and/or or access of your information outside of your country.

8. Accuracy of Personal Data

We do our best to ensure that the personal data we hold, and use is accurate. We rely on you to disclose to us all relevant information and to inform us of any changes.

9. Your Access to your Personal Data and Deletion Upon Request at Departure

Reasonable access to your personal data may be provided upon request made to 2HR Learning at the contact information provided below. If access cannot be provided within a reasonable time frame, 2HR Learning will provide the requesting party a date when the information will be provided. If for some reason access is denied, we will provide an explanation as to why access has been denied. We may charge a reasonable fee in advance for copying and sending the information requested.

If you would like us to delete any personal data held about you when you complete your education or otherwise choose to depart 2HR Learning, we will do so on request unless (i) we need to hold the information as required by applicable law, (ii) the information is held pursuant to a reasonable retention schedule and the information concerns academic records related to the education of the student, and (iii) it is aggregated and de-identified information as set forth in the Privacy Policy.

10. Your Choices

In certain circumstances we offer those who provide personal data a means to choose how we use the information provided. Where you have consented to the processing of your personal data, you may withdraw that consent at any time and prevent further processing by contacting us as described below.  Even if you opt out, we may still collect and use non-personal data regarding your activities on 2HR Learning Technology and for other legal purposes as described above.

Marketing. You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of our marketing emails. Note that you will continue to receive transaction-related emails regarding education or the 2HR Learning Technology. We may also send you certain non-promotional communications regarding us and 2HR Learning Technology, and you will not be able to opt out of those communications (e.g., communications regarding education or 2HR Learning Technology or updates to our terms or this Privacy Policy).

We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists as required by applicable law.

Mobile Devices. We may send you push notifications through our mobile application.  You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. We may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.

“Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers, except to the extent required by applicable law.

Cookies and Interest-Based Advertising. You may stop or restrict the placement of Analytics Systems on your device or remove them by adjusting your preferences as your browser or device permits.  The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs.  You can access these and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/. To separately make choices for mobile apps on a mobile device, you can download Digital Advertising Alliance’s AppChoices application from your device’s app store. Alternatively, for some devices you may use your device’s platform controls in your settings to exercise choice.

Please note you must separately opt out in each browser and on each device. Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.

11. Your Privacy Rights

Depending on where you reside, or in the future as privacy laws change, or based upon the Children’s Online Privacy Protection Act (“COPPA”) for children under 13 years of age, you may have the right to exercise additional rights available to you under applicable laws, including as applicable:

1. Right of erasure. You may have a broader right to erasure of personal data that we hold about you. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations, among other things.

2. Right to object to processing. You may have the right to request that we stop processing your personal data, including the right to opt in or opt out of the sale of your Personal Data to third parties, or to stop sending you marketing communications.

3. Right to restrict processing. You may have the right to request that we restrict processing of your personal data in certain circumstances. For example, where you believe that the personal data we hold about you is inaccurate or unlawfully held.

4. Right to data portability. In certain circumstances, you may have the right to be provided with your personal data in a structured, machine readable and commonly used format and to request that we transfer the personal data to another data controller without hindrance.

If you would like to exercise any of the above rights, or others that apply to you, or you believe that we should honor such right in your case, please contact us utilizing the contact details in the “Contacting Us” Section below. We will consider your request in accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity before complying with the request.

In some cases, our ability to uphold these rights for you may depend upon our obligations to process personal data for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the 2HR Learning Technology. Where this is the case, we will inform you of specific details in response to your request.

12. Children’s Privacy

The 2HR Learning Technology and other activities involve the collection and maintenance of personal data about children under 13, as well as other personal data of students, through use of the 2HR Learning Technology. It is operated by: 2HR Learning, 2028 E Ben White Blvd, Ste 240-2650, Austin, TX 78741. Please contact us at /a> with any questions about the collection, use and sharing of children’s personal data, and specifically the personal data of children under 13 years old, including requesting a list of our service providers acting as sub-processors.

2HR Learning may amend this Privacy Policy at any time by posting a new version online at https://2hr.school/privacy-policy/. It is your responsibility to review this Privacy Policy periodically as your continued use of the 2HR Learning Technology represents your agreement with the then-current Privacy Policy. If applicable data protection law requires additional affirmative consent from you for a new collection, use and disclosure of personal information, we will contact you to secure such consent.

15. Contacting Us

To contact us for questions or concerns about our privacy policies or practices please reach out to us at privacy@2hr.school.

Last Updated: August 22, 2023