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1. General

The Comprehensible Classroom, LLC (“Garbanzo”, “we”, “us” or “our”) takes your privacy seriously and is committed to safeguarding your privacy online. This Privacy Policy (“Privacy Policy”) details the personal data received about you, how we process it and your rights and obligations in relation to your personal data. The Comprehensible Classroom, LLC, is a company registered at PO Box 512, Charlotte, VT, 05445, United States of America.

By using or accessing Garbanzo's website, (the “Website”) and related services (together with the Website, the “Service”), you agree to the terms of this Privacy Policy. Capitalized terms not defined here have the meanings set forth in the terms and conditions (the “Terms and Conditions”), located at

It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users' personal information, we will notify you by email to the email address specified in your account and through a notice on the Website home page. The date the Privacy Policy was last revised is identified at the bottom of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Policy to check for any changes.

2. Information We Collect

This Privacy Policy explains how we collect, use and share your personal data.

(a) Information you may provide

  • Through the registration process, you will provide us with your name, email address (or parent's email address), and age or date of birth.
  • You will also provide us with your payment transaction information if you choose to pay for Garbanzo services.
  • We may retain records and copies of your correspondence, if you contact us.

(b) Activity Data

When you use the Service, we will generate data about your use of the Service including your engagement in educational activities on the Service, such as the completion of lesson plans and accrual of points relating to the completion of lessons (“Activity Dat”). We also collect technical data about how you interact with our Service; for more information, see Cookies.

(c) Third Party Data

We do not collect information about you from third parties.

3. Product Research and Development

We may contact you to participate in product research activities. These may include surveys, interviews, and other types of feedback sessions. When you participate in these research activities, the information you provide will be used to test, improve, and develop our products. We will record the text of this feedback together with any additional contact information you provide and will retain this data for two years.

Please contact us at [email protected] to:

  • Request more information about the research activities you have volunteered for.
  • Opt out of being contacted for research activities.
  • Request a copy of any research related data you have provided to us.

4. Cookies

When you enter the Website, we collect your browser type and your IP address (a unique address that identifies your computer on the Internet).

In addition, we store certain information from your browser using “cookies.” A cookie is a piece of data stored on the user's computer tied to information about the user. We use session ID cookies to confirm that users are logged in. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to deny or accept the cookie feature; however, you should note that cookies may be necessary to provide you certain features available on the Website (e.g., customized delivery of information). In addition to using this to enhance your user experience, we may use it to market our services to you.

You can find more information about cookies and how to manage them at

5. Information Obtained by Third Parties

We use Google Analytics which is a web analytics tool that helps us understand how users engage with the Website. Like many services, Google Analytics uses first-party cookies to track user interactions as in our case, where they are used to collect information about how users use our site. This information is used to compile reports and to help us improve our Website. The reports disclose website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you visit our site — for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page:

6. Use of information obtained by Garbanzo

We use personal data collected through the Service, including Activity Data to present our Website to you and provide you the Service. As a business, it is critical that we provide you with the best service possible, and it is in our legitimate interests to perform these processing functions and to enable service emails by default to keep your data secure and provide our Service. You may opt out of any non-essential service emails at any time by emailing [email protected].

Garbanzo may also occasionally send you service related and product change announcements through the general operation of the Service. We will send you reminder notifications to support the Garbanzo teaching methodology. We process your data to help provide you with the Service and offer personalized features, to understand and improve our Service and to keep our Service safe and secure.

We may also use your contact information to send you notifications regarding new services, offers and promotions offered by Garbanzo unless you notify us by emailing [email protected] that you do not wish to receive such communications.

Profile information is used by Garbanzo to be presented back to and edited by you when you access the Service. Garbanzo uses this information to provide you with support, to send you essential notifications, to enforce our terms, conditions and policies, to communicate with you, to administer the Service, and for internal operations, including troubleshooting, data analysis, research, statistical, and survey purposes. Garbanzo's Terms and Conditions provide the contractual lawful basis for these processing activities.

7. Sharing your personal data with third parties

Garbanzo shares your personal data only when it is necessary to offer the Service (including to our affiliates, and service providers), legally required, or permitted by you. In the event of the sale of Garbanzo or its assets or a merger involving Garbanzo, we may disclose your information to the acquirer or other merging party. We do not sell your personal data to any third parties.

We may provide personal data to hosting providers such as Amazon Web Services, search engine providers such as Google, analytics providers such as Crashlytics, and support providers such as ZenDesk.

These data processors help us bring you the Service. For example, we may share your information in order to detect where or how you encountered a bug when using our mobile application. In connection with these operations, our service providers will have access to personal data for a limited time. When we utilize service providers for processing any personal data, we implement contractual protections limiting the use of that personal data to the provision of services to Garbanzo.

We will be required to access and disclose personal data in response to lawful requests, such as subpoenas or court orders, or in compliance with applicable laws. Additionally, we will access and share account or other personal data when we believe it is necessary to comply with law, to protect our interests or property, to prevent fraud or other illegal activity perpetrated through the Service or using the Garbanzo name, or to prevent imminent harm. This will include accessing and sharing personal data with other companies, lawyers, agents or government agencies.

If the ownership of all or substantially all of the Garbanzo business, or individual business units or assets owned by Garbanzo that are related to the Service, changes, your personal data will be transferred to the new owner. In any such transfer of information, your personal data would remain subject to this section.

Garbanzo will share aggregate or anonymous data collected through the Service, including Activity Data, for purposes such as understanding or improving the service.

8. Data subject protections and data retention

All data is transferred over HTTPS (Hypertext Transfer Protocol Secure). Passwords are salted and stored encrypted at rest. The application itself is behind multiple firewalls and access to databases is closely restricted and monitored. We use multiple tools to monitor the health of the application and alert us to suspicious activity.

We have never had a data breach but in the event one occurs, we will notify affected customers as quickly as possible (and in accordance with any and all applicable laws or regulations) once we've determined the scope of the breach and have restored the integrity of the application.

You can manage your account settings at to update, amend, and correct your information.

We will also endeavor to provide you with the following rights, unless provided otherwise by local law:

  • To request access to, or erasure of, the personal data we hold about you.
  • To request us to restrict the processing of the personal data we hold about you.
  • To object to us processing personal data relating to you.
  • Where you have given us consent to process your personal data, you may withdraw that consent at any time.
  • To export the personal data you have provided to Garbanzo in a format that can be transferred electronically to a third party.
  • To delete your account with Garbanzo by following the instructions available through the Service.

To make a request with respect to the foregoing, users should email [email protected].

Garbanzo will retain your data until your account is deleted, after which point we will retain anonymous data collected through the Service, including Activity Data, which may be used by Garbanzo and shared with third parties in any manner.

Please note that some of these rights are not absolute. In some cases, we may refuse a request to exercise particular rights if complying with it means that we are no longer able to meet our contractual obligation to provide you with particular products and services. We will keep you informed as to the actions that we can take when you make your request.

9. Third party websites and links

For users who are teachers, our Service may contain links to other sites operated by third parties. Garbanzo does not control such other sites and is not responsible for their content, their privacy policies, or their use of personal data, including any personal or financial information collected by our third party payment processor. Garbanzo's inclusion of such links does not imply any endorsement of the content on such sites or of their owners or operators except as disclosed on the Website. Any information submitted by you directly to these third parties is subject to that third party's privacy policy.

10. Website for individuals in the United States Only

This Website and the Service are intended for individuals located in the United States only.

11. Children under age of 13

Garbanzo provides some features and services intended for use by children. The Children's Online Privacy Protection Act of 1998 and its rules require us to inform parents and legal guardians (as used in this section “parents”) about our practices for collecting, using, and disclosing personal information from children under the age of 13 (“children”). It also requires us to obtain verifiable consent from a child's parent for certain collection, use, and disclosure of the child's personal information. Children aged 13 years or younger must provide a parent's email address, and Garbanzo will only permit use of the Service when it has received parental consent as described further below.

This section only applies to children under the age of 13 and supplements the other provisions of this Privacy Policy. Only the other provisions of this Privacy Policy apply to teens and adults. Except where noted in this section, all information provided in other sections of the Privacy Policy apply to children as well as to older users of the Service.

This section notifies parents of any deviations from Garbanzo's general privacy policies with respect to children relating to the following:

  • The types of information we may collect from children.
  • How we use the information we collect.
  • Our practices for disclosing that information.
  • Our practices for notifying and obtaining parents' consent when we collect personal information from children, including how a parent may revoke consent.
  • All parties that collect or maintain information from children through this Service.

We only collect as much information about a child as is reasonably necessary for the child to participate in an activity, and we do not condition his or her participation on the disclosure of more personal information than is reasonably necessary. In order for a child to register for the Service, he or she must provide his or her name, birthday, and the email address of a parent. We also track Activity Data of children and use cookies with respect to computers used by children. See our Activity Data and Cookies for more information. We do not collect credit card or other payment information from children.

Upon registration the child will provide a parent's email address, to whom Garbanzo will send a notification. Garbanzo will not complete the registration of a child until it has received email permission from the parent and sent the parent a confirmation email.

Garbanzo uses age-gating to restrict what services are available to children. Children will receive the following service restrictions:

  • Instead of storing a child's email address, we will only store the email address of his or her parent.
  • To the extent that Garbanzo establishes any ability for some users to post information publicly or to other users of the Garbanzo community, such as in a chat room, children will be prevented from posting.
  • To the extent that Garbanzo allows some users to contact each other via email, children will be not be assisted in sending or receiving email.
  • Children will not be presented with links to other websites.

At the point when the user is known to have reached the age of 13, the account will automatically be transitioned to be a normal non-restricted account.

At any time, you may review the child's personal information maintained by us, require us to correct or delete the personal information, and/or refuse to permit us from further collecting or using the child's information.

You can review, change, or delete your child's personal information by:

  • Logging into your child's student account and visiting his or her account profile page.
  • Sending us an email at [email protected]. To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections.

12. Information security

Garbanzo has implemented administrative and technical safeguards it believes are appropriate to protect the confidentiality, integrity and availability of your personal data and access credentials. However, given sufficient resources, a determined attacker could defeat those safeguards and may, as a result, gain access to the data we seek to protect. In the event a malicious attack is successful and user data is affected, we will immediately notify all affected customers.

13. Do Not Track

The Service is not designed to respond to “do not track” signals sent by some browsers.

14. Contact Us

Garbanzo's headquarters are located at:

PO Box 512
Charlotte, VT 05445
United States of America

For all data privacy inquiries and any questions or concerns you have about this Privacy Policy, please contact us at [email protected].

Last revised on July 28, 2021.

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