Privacy Policy

General

Garbanzo (“Garbanzo”, “we”, “us” or “our”) takes your privacy seriously and is committed to safeguarding your privacy online. This Privacy Policy (“Privacy Policy”) details how we collect, use, and disclose your personal data when you interact with our website https://garbanzo.io (the “Website”), and related services (together with the Website, the “Services”) or when you otherwise interact with us, such as through our customer support channels, or on social media pages and your rights and obligations in relation to your personal data. Users of our Services (each, a “User”) include eligible individuals who sign up with a teacher account (each, a “Teacher”) or students who create a student account in response to an invitation link sent by Us, on behalf of a Teacher, (each, a “Student”). The kinds of personal data we collect and our purposes of use depend on the type of User you are. For Students, we process personal data only for educational purposes on the instructions of Teachers, and not for our own or commercial purposes. If you are a Student and have questions about the specific personal data we collect, use, or disclosure on the instructions of Teachers, we recommend consulting with your Teacher first. Garbanzo, is a company registered at PO Box 512, Charlotte, VT, 05445, United States of America. Capitalized terms not defined here have the meanings set forth in the terms and conditions (the “Terms and Conditions”), located at https://garbanzo.io/terms.

We may change this Privacy Policy from time to time. If we make changes, we will notify Users by revising the date at the bottom of this policy. If we make material changes, we will provide you with additional notice, such as 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. We encourage you to have an up-to-date, active, and deliverable email address for your account and to periodically visit our Website and this Privacy Policy to check for any changes.

CONTENTS

Information We Collect
Use of Information
Disclosure of Information
Data Retention
Third Party Websites and Links
Transfer of Information to the United States and Other Countries
Children Under 13
Contact Us

1. Information We Collect

The categories of personal information we collect and the sources from which we collect it depend on your User type and your interactions with us and are described in more detail below.
Information Collected from All Users.
- Information You May Provide. We collect information you provide directly to us, including when Users engage in any of the activities listed below:
  - Register for an account and provide us with your name, email address (or parent's email address, if you are a Student), and age or date of birth, if you are a Student.
  - If you are a parent or legal guardian of a Student (each, a “Parent”), provide us with consent for collection of your child’s data, as described below.
  - Reach out to contact us or fill out a form on our Services, such as in connection with customer support or feedback.
- Information Collected Automatically. We collect certain information automatically, including when Users access or use our Services, we automatically collect certain information, including:
  - Activity Data. When you use the Services, we will generate data about your use of the Services including your engagement in educational activities on the Services, such as the completion of lesson plans and accrual of points relating to the completion of lessons (“Activity Data”). We also collect technical data about how you interact with our Services; for more information, see “Information Collected by Cookies and Similar Tracking Technology” below;
  - Device and Usage Information. We collect information about how you access and use our Services, including data about the device and network you use, such as your hardware model, operating system version, mobile network, unique device identifiers, your browser type and your IP address (a unique address that identifies your computer on the Internet); We also collect information about your activity on our Services, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Services; and
  - Information Collected by Cookies and Similar Tracking Technology. When you enter the Website, we collect your browser type and your IP address. 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). You can find more information about cookies and how to manage them at http://www.allaboutcookies.org.
- Information We Collect from Other Sources.
  - Third Party Login. We may obtain information from other sources. For example, if you create or log into your Garbanzo account through a third-party platform (such as Google), we will have access to certain information from that platform, such as your email address, a randomized identifier provided by the third party, and, in some cases, a first name or initial, in accordance with the authorization procedures determined by such platform; and
  - Third Party Integrations. Teachers decide which data is integrated with Garbanzo, and Teachers are responsible for determining whether data is ever shared with applications through Garbanzo.
- Information We May Derive.
  - We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your approximate location based on your IP address.
Information Collected from Teachers.
In addition to collection of data as described in Section 1(a) above, we collect certain additional information from Teachers.
- Information Teachers May Provide Directly. We collect information directly from Teachers when you engage in any of the activities listed below:
  - Submit or post content through our Services;
  - Make a purchase on our Services; and
  - Provide content in connection with product research activities that you may choose to participate in at our request. These may include surveys, interviews, and other types of feedback sessions.
- Information We Collect Automatically from Teachers. We collect certain information automatically from Teachers, including:
  - Transactional Information. When you make a purchase or return, we collect information about the transaction, such as product details, purchase price, and the date and location of the transaction.
Information Collected from Students. In addition to collection of data as described in Section 1(a) above, we may collect personal information from Students (“Student Data”) only if Teachers or Parents provide us with access to Student Data. Students do not otherwise provide Student Data to us.

2. Use of Information

The way we use your personal data depends on your User type and is described in more detail below.

Use of Information for Students.
When we process Student Data, we do so solely to provide the Services for educational purposes only and at the specific direction of the Teacher. Garbanzo does not own or control Student Data. Garbanzo does not advertise or market to Students. No personally identifiable Student Data will be used for marketing purposes.
Use of Information of All Users (other than Students).
For all Users other than Students, we use the personal data we collect to present our Website to you and provide you the Services. We also use the personal data we collect to:
- Comply with our legal and financial obligations;
- Detect, investigate, and help prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and help protect the rights and property of Garbanzo and others;
- Create de-identified, anonymized, or aggregated information; and
- Carry out any other purpose described to you at the time the information was collected.
Use of Information of Teachers.
For Teachers, in addition to the uses disclosed above, we use your personal data for the following purposes:
- Send you service related and product change announcements through the general operation of the Services. We will send you reminder notifications to support the Garbanzo teaching methodology;
- Provide you with the Services and offer personalized features, to understand and improve our Services and to keep our Services safe and secure;
- 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;
- Provide you with support;
- Send you essential notifications, technical notices, security alerts, support messages, and other transactional or relationship messages;
- Facilitate internal operations, including troubleshooting, data analysis, research, statistical, and survey purposes; Monitor and analyze trends, usage, and activities in connection with our products and services;
- Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards;
- For any data provided via your participation in our research activities, test, improve, and develop our products; and
- For limited internal uses, provided the personal information is not disclosed to another third party and is not used to build a profile about you.

3. Disclosure of Information

In certain circumstances, Garbanzo discloses your personal data. We disclose personal data in the following ways:

Disclosure of Information about Students.
For Students, we disclose Student Data to third party service providers strictly as necessary to provide the Services to Teachers.
Disclosure of Information of Teachers and All Other Users (other than Students).
For all Users other than Students, 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.
- Law Enforcement Authorities and Individuals Involved in Legal Proceedings. We may disclose personal data in response to lawful requests, such as subpoenas or court orders.
- Corporate Transactions. In connection with, or during negotiations concerning, any reorganization, joint venture, assignment, transfer, financing, or acquisition, sale, or other disposition of all or any portion of Garbanzo or its assets or a merger involving Garbanzo, we may disclose your information.
- To Protect the Rights of Garbanzo and Others. We may disclose 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 Services or using the Garbanzo name, or to prevent imminent harm.
- Professional Advisors. We may disclose your personal data with our lawyers, financial, insurance, and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
- Consent. We make personal data available to third parties, such as Mailchimp, when we have your consent or you intentionally direct us to do so.
- Corporate Affiliates. Personal data is disclosed between and among Garbanzo and our parents, affiliates, subsidiaries, and other companies under common control and ownership.

For all Users, Garbanzo may also disclose aggregate or de-identified anonymous data that cannot reasonably be used by recipients to identify you. We will not attempt to re-identify such information, except as permitted by law. We do not sell your personal data to any third parties.

4. Your Privacy Choices

You can access, update, correct, amend, and delete certain personal data we hold about you by logging into your account and following the instructions available through the Services or contacting us at [email protected]. If you wish to deactivate your account, please contact us at [email protected] or follow the instructions available through the Services, but note that we may retain certain information as required by law or for our legitimate business purposes.

For Students, if you wish to better understand the Student Data we process about you on behalf of your Teacher or to otherwise exercise the actions described above and cannot do so through your account, please contact your Teacher who may authorize us to take those actions.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services. You can opt out of cookies provided by 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: https://tools.google.com/dlpage/gaoptout.

Communications Preferences

Teachers may opt out of receiving promotional emails from Garbanzo by following the instructions in those communications or by following the instructions provided by our Services or emailing us at [email protected]. Additionally, you may opt out of any other non-essential service emails at any time by emailing [email protected]. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

Product Research and Development

Teachers may voluntarily participate in product research and development. If you are a Teacher who has participated in these activities, 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.

We will not discriminate against you if you exercise your privacy rights.

5. Data Retention

Garbanzo will retain your data until your account is closed, after which point, we will delete your account data; otherwise we will delete your account data after a period of inactivity. For any of your data that we retain in connection with voluntary participation by Teachers in product research and development, we will retain this data for two years from collection. For other personal data of non-Students and Teachers, we store it for as long as necessary to carry out the purposes for which we originally collected it and for other business purposes described in this Privacy Policy.

6. Third Party Websites and Links

For users who are Teachers, our Services 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.

7. Information Storage within the United States

Garbanzo is headquartered in the United States and we have operations and vendors located only within the United States.

This Website and the Services are intended for individuals located worldwide.

8. Children Under the Age of 13

Garbanzo provides some features and services, on the instructions of Teachers, intended for use by Students under the age of 13 (“Children” or “Child”). The Children's Online Privacy Protection Act of 1998 (“COPPA”) and its rules require us to inform Parents about our practices for collecting, using, and disclosing personal information from 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.

This section only applies to personal data of 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, all information provided in other sections of the Privacy Policy apply to Children as well as to other users of the Services.

Garbanzo is the only operator who collects and maintains information from Children through our Website and Services. Children’s data is collected, used, and disclosed in the ways explained in Sections 1-3 above pertaining to Student Data. 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.
- Children’s data is collected as described in Section 1 above, pertaining to Student Data.
How we use the information we collect.
- Children’s data is used as described in Section 2 above, pertaining to Student Data.
Our practices for disclosing that information.
- Children’s data is disclosed as described in Section 3 above, pertaining to Student Data.
Our practices for notifying and obtaining Parents’ consent when we collect personal information from Children, including how a Parent may review or delete the Child’s personal information and revoke consent for future collection or use.
- COPPA requires that online service providers such as Garbanzo, or Teachers/schools acting as a Parent’s agent, provide parental notification and obtain parental consent before knowingly collecting personal/individually identifiable information from Children under the age of 13, except in limited situations (for exceptions to this consent requirement, please see 16 CFR § 312.5(c)).

If such personal information is collected without parental consent or collected beyond the scope needed for participation in the Services, we will delete such information as soon as possible. If you believe that information from a Child under the age of 13 has been provided in violation of these terms, please contact us at [email protected].

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.

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.

9. Contact Us

Garbanzo's headquarters are located at:

Garbanzo
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 3, 2024

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