Sumdog Inc. Privacy Notice

Last updated December 18, 2023

This Privacy Notice describes the information collection, use, retention and sharing practices of Sumdog Inc. (“Sumdog”, “we”, “us”, “our”) when you interact with us through our websites, https://learn.sumdog.com, https://content.sumdog.com, https://blog.sumdog.com, https://support.sumdog.com, https://play.sumdog.com and https://sumdog.com  (the “Websites”) or other digital products on which this Privacy Notice appears (collectively, the “Services”). 

As used in this Privacy Notice, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person.  

PERSONAL INFORMATION WE COLLECT, WHY AND FOR HOW LONG 

We collect personal information as you engage with our Services.

If you are a Teacher User, this includes when you: 

• Sign up for Sumdog as a Teacher User. When you sign up for Sumdog as a Teacher User, we collect, from you, your personal identifiers (name, email address), your professional or employment-related information (school name and address, job title), and your sensitive login details (password) in encrypted format. If you sign up via Google SSO, we will not collect your password and your usage of the SSO will be governed by the relevant Google policies. We use this information to create and manage your Teacher User account and to send you news and updates about Sumdog. You may unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of each email we send to you. However, we will continue to send you service-related messages. Our emails include a tracking pixel that tracks whether you open the email, whether you click banners in the email, and your subsequent clicks and usage of our Websites. We use this information to send you additional email communications which may be of interest to you, as based on your interaction with our emails and/or Websites. You can avoid downloading the pixel by rejecting the download of images in the email. Further, if you do not confirm your email address within 30 days of signing up, we will automatically delete your information. If you are a Teacher User without a Sumdog subscription and you have not logged on in 12 months, we will use your email address to send you a notification email to log in to keep your account active. Inactive accounts may be deleted after 15 months. Upon deletion, your personal information will be anonymized. Please note that Student User accounts linked to your Teacher Account may be deleted at the same time as your Teacher User account.
  
  
• Sign up for a Sumdog professional development course. When you sign up for a Sumdog professional development course, we collect, from you, your personal identifiers (name and email address) and your sensitive login details (password). We use this information to sign you up for the selected Sumdog professional development course. We retain this information for as long as you have a Sumdog account.
  
  
• Buy a class. When you buy a class, we collect from you or from our third-party payment processor Stripe, your personal identifiers (name and email address), your professional or employment-related information (school name and zip code), and your sensitive financial information (credit or debit card number, CVV, expiration date). We use this information to process your payment. However, your sensitive financial information is held with Stripe and is not accessible to us. Please see Stripe’s Privacy Policy for information regarding Stripe’s collection and use of personal information.
  
  
• Invite other teachers to your Sumdog School. When you invite other teachers to your Sumdog School, we collect, from you, your invitee’s personal identifier (email address). We use this information to add your invitee to your Sumdog School. We retain this information for as long as the account remains active. Please ensure that you have the permission of anyone you invite to share this information with us.
  
  
• Use the Sumdog Service. When you use the Sumdog Service, we automatically collect, through cookies and similar technologies, your internet or other electronic network activity information (usage data (e.g., time stamps)), your online identifiers from the last two logins (IP address), and your usage information (e.g., work set, coins earned). We use this information to create aggregated usage reports and to understand how teachers are using the Sumdog Service. We retain this information for as long as your account exists, unless specified otherwise.
  
  
• Create a Student User account. When a teacher, parent or guardian creates a Student User account, we collect, from you, the student’s personal identifiers (name and grade). We use this information to create and manage the Student User account, to place the student at the correct level in the Sumdog curriculum and to facilitate the student’s participation in a Sumdog contest. After the Student User account is created, Sumdog will create and share with you the Student User login information. You can reset the Student User login information at any time. 
  
  Teacher Users can access the name, class, grade or age, avatar, login information, usage information and educational progress information of Student Users linked to their Sumdog School. 

If you are a Parent User, this includes when you: 

• Sign up for Sumdog as a Parent User. When you sign up for Sumdog as a Parent User, we collect, from you, your personal identifiers (name, email address), your sensitive financial information (credit or debit card number, CVV, expiration date), and your sensitive login details (password). We use this information to create and manage your Parent User account, to process payments, and for verification purposes in accordance with laws addressing children and student information. If you create a free trial, we collect the same information and use it to create and manage your family account and to enroll you in our free trial. Your sensitive financial information is held with our third-party payment processor Braintree and is not accessible to us. Please see Braintree’s Privacy Policy for information regarding Braintree’s collection and use of personal information. If you do not subscribe, we will anonymize your information within three months. If you opt out of the renewal within 30 days of signing up or decide to cancel your subscription at a later time, we will anonymize your information within three months of the opt-out. Please note that Student User accounts linked to your Parent Account may be deleted at the same time as your Parent User account. If your subscription continues, we will use your sensitive financial information to process your payment for subsequent subscription period(s) in accordance with our Terms of Use via our provider, Braintree (see above).
  
  
• Invite other parents/guardians to Sumdog Family. When you invite other parents or guardians to your Sumdog Family, we collect, from you, your invitee’s personal identifiers (name and email address). We use this information to add your invitee to your Sumdog Family. We retain this information for as long as the account remains active. Please ensure that you have the permission of anyone you invite to share this information with us.
  
  
• Create a Student User account. Student User accounts are created by a teacher, parent, or guardian. When you create a Student User account, we collect, from you, the student’s personal identifiers (name and date of birth). We use this information to create and manage the Student User account and to place the student at the correct level in the Sumdog curriculum. After the Student User account is created, Sumdog will create and share with you the Student User login information. You can reset the Student User password at any time.
  
  Parent Users may access their Student User child’s name, class, grade or age, avatar, login information, usage information and educational progress information.  

For Student Users, this includes when the student: 

• Updates their Student User profile. When a student updates their Student User profile, we collect, from the student, their profile details (favorite Sumdog game, Sumdog pet and pet name), their house and garden in-service purchases, and their on-screen avatar preferences (visual appearance). We use this information to update the student’s Student User profile. We retain this information for as long as the Student User account exists. If a Student User account is associated with a school account, we will retain this information until the last Teacher User account associated with such school remains inactive for 15 months, after which it becomes anonymized. If a Student User account is only associated with a Parent User account, we anonymize the information three months after the subscription is cancelled.
  
  
• Adds a friend. When a student submits a request to add a friend to their Student User account, we receive, from the student, a unique code to facilitate the friend request. Once the students become Sumdog friends, they can then view each other’s avatar, school, coin total, and animal rank, as well as send each other gifts for their Sumdog house, garden or avatar. However, Sumdog has no social features that allow Student Users to communicate freely. Student Users can remove friends at any time and choose to decline any friend requests.
  
  
• Uses the Sumdog Service. When a student uses the Sumdog Service, we automatically collect, the student’s internet or other electronic network activity information (usage data (e.g., time stamps)), the student’s online identifiers from their last two logins (IP address), and the student’s education information (progress data (e.g., accuracy, place in the curriculum)). We use this information to provide and maintain the service by: (i) monitoring the progress of the student; (ii) adapting question content and modify the level of difficulty of questions the student receives; (iii) creating student diagnostic reports (which are then shared with parent and teachers); (iv) diagnosing and repairing errors; and (v) allocating coins to the student’s profile, when earned. We retain this information for as long as the Student User account exists, unless specified otherwise.
  
  
• Takes part in a Sumdog contest. When a student is entered into a Sumdog contest, we automatically collect, through cookies and similar technologies, the student’s internet or other electronic network activity information (usage data (e.g., time stamps)). We use this information, together with personal identifiers (name) to create contest leaderboards and show the student their progress in the contest.
  
  
• Gives us feedback. Occasionally, students will be asked whether they are enjoying using Sumdog. Feedback is collected in the form of an emoji. We use this information, in an aggregated manner, to measure satisfaction rates and understand how this changes over time.     

Some of the information provided about Student Users may be accessed by the Parent Users in their Sumdog Family, or the Teacher Users linked to their Sumdog School. This may include their name, class, grade or age, avatar, login information, usage information and educational progress information.  

Additionally, when a Parent User or Teacher User submits any personal information relating to a Student User, the Parent User or Teacher User represents that they have the authority to do so. 

If you are a website visitor, this includes when you: 

• Contact us. When you contact us, we collect, from you, your personal identifiers (name, email address, zip code), your “role” (i.e., teacher, parent, math coordinator, teaching assistant), your Sumdog product interests, and any additional information you choose to include in your message. We use this information to respond to your questions or inquiries or to communicate with you about scheduling a live demo. We retain this information for 12 months after you have retracted consent to our communications.
  
  
• Email us. When you email our support team, we collect, from you, your personal identifiers (name, email), and any additional information you choose to include in your message. We use this information to respond to your questions or inquiries. We retain this information for 12 months after your ticket is closed.
  
  
• Provide app reviews. When you provide app reviews or comment on our app store pages, we collect, from you, your interactions with the app store pages, including “likes”, comments, reviews, and ratings. We use this information to improve our Services and generate feedback. Because this information is publicly accessible, be mindful that it can be viewed by others or used by them as they see fit.
  
  
• Interact with us on social media. When you interact with our social media pages on social networking Websites, such as Facebook, LinkedIn, X, Instagram, YouTube, TikTok, and Pinterest (each, a “Social Media Page” and collectively, “Social Media Pages”), we collect basic engagement metrics and use it to tailor content and marketing and use it to improve user experience as set forth in this section. Please note that we do not control the use or storage of the information that you have posted to any social networking Websites. This information is collected and processed by the social networking Websites for their own purposes, including marketing. For more information on how Facebook, LinkedIn, X, and Instagram use your personal information, please see Facebook’s Privacy Policy, LinkedIn’s Privacy Policy, X’s Privacy Policy, Instagram’s Privacy Policy, YouTube’s Privacy Policy, TikTok’s Privacy Policy, and Pinterest’s Privacy Policy.  

• Social Media Pages. When interacting with our Social Media Pages, we collect, from you, your personal identifiers (name and profile picture) as well as any information that you provide when interacting with our Social Media Pages (e.g. commenting, sharing and rating). We use this information to advertise our products, for events and invitations, and to communicate with users via the contribution and comment function. 
  Because our Social Media Pages are publicly accessible, when you use them to interact with other users, for example by posting, leaving comments or liking or sharing posts, any personal information that you post in them or provide when registering can be viewed by others or used by them as they see fit.
  The content posted on our Social Media Pages or other public areas of social networking Websites can be deleted in the same way as other content that you have created. If at any time you want content posted to be deleted, please email your request to privacy@sumdog.com.
  
  
• Facebook Messenger; Direct Messages. When using Facebook Messenger or other direct message capabilities on Social Media Pages, the applicable Social Media Page collects, automatically, your internet or other electronic network activity information (IP address, date and time of the server request, time zone, specific browser or app function, access status, amount of data transferred, browser or app from which the Request comes, device type, operating system used, and its interface (e.g. Android or IOS), language, version of the operating system, and device identifiers). We do not use this information; its use is governed by the applicable Social Media Page’s Privacy Policy, a hyperlink to which is available above.
  
  
• Facebook Page Insights. When you visit our Facebook Social Media Page, Facebook records your IP address and other information about your usage behavior on our Facebook Social Media Page. Facebook collects, through trackers in the browser of your device or via the advertising ID (IDFA from Apple or GAID from Google), when you open the Facebook app through your mobile device (e.g. smartphone or tablet). Facebook uses this information to create statistical evaluations for us of the use of the Social Media Page. We receive this information, from Facebook, in the form of aggregated data and anonymous statistics regarding things like: age, gender, city/country, device, inquiries from fans about other Facebook fan pages, region and language settings of the users, proportion of men and women, the number of people reached, clicks on posts, "Likes” and reactions, comments and shared content, and total video views. We do not collect or process any other personal data in connection with the page insights.
  We do not retain this information independently. For information on data protection and the storage period on Facebook in relation to the "Page Insights" function see here and Facebook’s Privacy Policy. It has been contractually agreed with Facebook that Facebook is responsible for providing you with information about the processing for Page Insights.
  
  
• Information Processed Solely by Facebook. We do not know how Facebook uses personal information for its own purposes, how long the personal information is stored on Facebook or whether Facebook data is passed on to third parties
  If you are currently logged in to Facebook as a user, Facebook automatically collects, through trackers on your device, your Facebook ID or a link between the Facebook ID and the advertising ID (IDFA from Apple or GAID from Google) when you open the Facebook app through your mobile device (e.g. smartphone or tablet). This enables Facebook to understand that you have visited our Facebook Social Media Page along with other Facebook pages that you have clicked on, whether you clicked on Facebook buttons integrated into Websites that partner with Facebook, and other online interactions that report user data to Facebook. Based on this data, content or advertising tailored to you can be offered. 

• Google Analytics. We use Google Analytics to collect information on your use of the Websites for their improvement. To collect this information, Google Analytics installs cookies on your browser or reads cookies that are already there. Google Analytics also receives information about you from applications you have downloaded that partner with Google. However, please note we have enabled restricted processing. Please see Google’s Terms of Use and Privacy Policy for more information. 
  
  
• DoubleClick. We utilize DoubleClick by Google to serve ads based on a user’s prior visits to our Websites. Each visitor to our Websites receive a different cookie, and the information collected by the cookie is used to generate conversion statistics and allows us to see the total number of individuals who clicked on our ads. DoubleClick enables Google and its partners to serve ads to you based on your visits to our Websites in addition to other Websites on the Internet. Please review Google’s Privacy Notice for additional information on how Google uses the information collected. If you previously opted in, you can opt out through Your Privacy Rights. You can also go to Google’s Ad Settings, or you can install the DoubleClick opt-out add-on.
  
  
• HubSpot. We use HubSpot to analyze the data traffic on our Websites and your behavior while using our Websites, which includes page visits, clicks, text entered, and other details. We use this information to gain insights into user behavior on our Website, to enhance website functionality, and to deliver targeted advertisements. We also use HubSpot to send our emails and to track the behavior of our email recipients. With the help of HubSpot’s conversion tracking, we can analyze whether a predefined action took place by an email recipient, such as opening our email, in order to better adapt and distribute our emails. For more information on HubSpot’s use and collection of personal information, please review its Privacy Policy. You can disable email tracking by disabling the display of images by default in your email program. If you previously opted in, you can opt out through Your Privacy Rights.  
  
  
• Aggregate and deidentified data. We aggregate the data we collect for benchmarking purposes and for internal analytics. We maintain and use this data in deidentified form. We will not attempt to reidentify the data, unless it is necessary to determine whether our deidentification processes satisfy applicable data protection laws. 

Sumdog will also use the personal information we collect as described in this section to comply with the law, to efficiently maintain our business, and for other limited circumstances as described in HOW WE SHARE YOUR PERSONAL INFORMATION.

Unless otherwise stated in this Privacy Notice, we retain your personal information for as long as the relevant Sumdog account exists or until we no longer need your information to provide you with the Sumdog Service or otherwise fulfill the purposes for which we collected it – for the time periods stated above. However, we may need to use and retain your personal information for longer than the periods indicated above for purposes of: 

•    Compliance with our legal and ethical obligations. For example, retaining personal information where we are legally required to do so or required by our professional ethics rules. 
•    Meeting our safety and security commitments. For example, keeping our properties secure and preventing fraud.
•    Exercising or defending legal claims. We also may need to retain personal information for longer than the periods indicated above in order to respond to legal process or enforceable governmental requests, or to enforce our contracts or Terms of Use, including investigation of potential violations.

HOW WE SHARE YOUR PERSONAL INFORMATION

A.    General Sharing 

Sumdog shares personal information in the following instances: 

•    Within Sumdog. We share your personal information within Sumdog, as appropriate, to provide our Services and to efficiently maintain our business. 

•    With our affiliates. We share information with our affiliate (parent company) eEducation Albert AB and the eEducation Albert group family of affiliates (“eEducation”) as part of our regular reporting activities on company performance. Shared reports use aggregated information and personal information is not reidentified. In addition, eEducation can see some of our information in its role as a provider of our CRM system. Finally, eEducation gets access to some of our marketing campaign information in order to assist us with the campaigns.  Companies in the eEducation Albert group include:

o    eEducation Albert AB (publ)
o    Ampd AB
o    ARPU Management AB
o    Strawbees AB
o    Kids MBA SAS
o    Swedish Film AB (subsidiary of APRU Management)
o    Sumdog Ltd
o    Sumdog Inc

•    Sumdog games/contests. We share Student Users’ first name, last initial, class and school as part of a contest leaderboard, which can be seen by other Student Users that are logged-in, as well as by other schools. Contests are optional and are per the schools’ choice. We may also share Student Users’ first name, last initial and avatar as part of individual game leaderboards, which can be seen by other schools, as well as by other Student Users that are logged-in. Note that schools can choose to pseudonymize Student Users’ names. 

•    With teachers and parents/guardians. We share students’ diagnostic reports (educational progress data) with their parent/guardian and teachers. 

•    In the event of a corporate reorganization. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we would share personal information with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction. We will also share personal information with third parties if we undergo bankruptcy or liquidation, in the course of such proceedings.

•    For legal purposes. We share your personal information where we are legally required to do so, such as in response to court orders, governmental/regulatory bodies, law enforcement or legal process, including for national security purposes. We may share your information with our legal advisors or auditors to establish, protect, or exercise our legal rights or as required to enforce our terms of service or other contracts or to defend against legal claims or demands. We also share this information with third parties as necessary to: detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person; to comply with the requirements of any applicable law; or to comply with our legal obligations.

•    With your consent. Apart from the reasons identified above, we may request your permission to share your personal information for a specific purpose. We will notify you and request consent before you provide the personal information or before the personal information you have already provided is shared for such purpose. You may revoke your consent at any time and may do so by contacting us via email at privacy@sumdog.com. 

B.    Sharing in the Last Twelve (12) Months

For a business purpose. In the preceding twelve (12) months, Sumdog has disclosed the following categories of personal information for a business purpose to the following categories of third parties: 

•    We have disclosed your personal identifiers to service providers that assist us in providing the Services. These service providers assist us with the following: information technology (“IT”) support; data hosting; data analysis; customer relationship management; mailing; email delivery; professional services (lawyers, bankers, insurers, auditors, accountants); auto-rostering (for subscribed school accounts); purchase and payment; eSignature provider; error reporting; video/phone system; web analytics; and similar services.

•    We have disclosed your internet or other electronic network activity information collected by cookies to our IT support to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to identify and repair the Websites and platform errors.

•    We have disclosed your internet or other electronic network activity information collected by cookies to our cookie management provider.

C.    Sale of Personal Information

In the preceding twelve (12) months (assuming you have opted-in), Sumdog has shared your internet or other electronic network activity information collected via cookies and other tracking technologies with our data analytics/advertising providers as described in PERSONAL INFORMATION WE COLLECT, WHY AND FOR HOW LONG. To adjust your privacy preferences (opt-in or out), please visit Your Privacy Rights. Please note that advertising and analytics cookies are not deployed behind login walls.

SERVICE PROVIDERS THAT COLLECT OR MAINTAIN INFORMATION FROM STUDENT USERS

For purposes of children and student privacy laws (e.g. COPPA and FERPA), listed below are the names and contact details of service providers that collect or maintain Student Users’ personal information, as well as the purposes for processing and the categories of personal information they process:

YOUR INFORMATION CHOICES

You have the following choices with respect to your personal information: 

• Correct or view your information. You may access your account to correct or view certain personal information you have provided to us and which is associated with your account.
• Cookie preferences. To adjust your cookie preferences, please visit Your Privacy Rights.
• Opt out of email tracking. You can disable this tracking by blocking automatic loading of images in your email.
• Opt out of marketing communications. You may opt out of receiving marketing emails from us by clicking the “unsubscribe” link provided at the bottom of each email we send. Please note that we will continue to send you notifications necessary to the Services.
• General note on advertising cookies. All session cookies are temporary and expire after you close your web browser. Persistent cookies can be removed by following your web browser’s directions. To find out how to see what cookies have been set on your computer or device, and how to reject and delete the cookies, please visit: https://www.aboutcookies.org/. Please note that each web browser is different. To find information relating to your browser, visit the browser developer’s website and mobile application. If you reset your web browser to refuse all cookies or to indicate when a cookie is being sent, some features of our website may not function properly. If you choose to opt out, we will place an "opt-out cookie" on your device. The "opt-out cookie" is browser specific and device specific and only lasts until cookies are cleared from your browser or device. The opt-out cookie will not work for essential cookies. If the cookie is removed or deleted, if you upgrade your browser or if you visit us from a different computer, you will need to return and update your preferences. By clicking on the “Opt-Out” links below, you will be directed to the respective third-party website where your computer will be scanned to determine who maintains cookies on you. At that time, you can either choose to opt out of all targeted advertising or you can choose to opt out of targeted advertising by selecting individual companies who maintain a cookie on your machine.
  
  o    Network Advertising Initiative (NAI) Opt-Out: https://www.networkadvertising.org/managing/opt_out.asp 
  o    Digital Advertising Alliance (DAA) Opt-Out: https://optout.aboutads.info 
  o    European Union (EU) /European Economic Area (EEA) Opt-Out: http://www.youronlinechoices.eu
  o    In general, you can also disable cookies by setting your browser to refuse cookies or indicate when a cookie is being sent.
  
  

PARENT/GUARDIAN RIGHTS  

Parents and legal guardians at all times have the right to: 1) review their student’s personal information maintained by us; 2) require us to correct or delete the personal information; and/or 3) refuse to permit us from further collecting or using the student’s information. Please note that these requests should be submitted to the school; we will assist the school in complying with the requests. Access, correction, and/or deletion requests may be submitted to us directly through the Sumdog app so long as the student is part of a Sumdog Family. These requests can also be exercised via email by emailing our Data Protection Officer at privacy@sumdog.com. 

Please note, however, the following information will not be deleted in the event we receive a deletion request:  

•    After a request to delete a Sumdog Family, the Student User accounts will not be deleted if they are also linked with a Sumdog School.
•    After a request to delete a Sumdog School, the Student User accounts will not be deleted if they are also linked with a Sumdog Family. 

RIGHTS OF CALIFORNIA RESIDENTS ONLY

The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (collectively, “CPRA”) entitles California residents to certain rights. To the extent the CPRA applies to our processing of your personal information, you are entitled to the following rights: 

• Right to Access/Know. You have the right to request what personal information we have collected, used, disclosed, and sold about you, unless doing so proves impossible or would involve disproportionate effort. You may only make a request for access twice within a 12-month period.
• Right to Deletion. You have the right to request the deletion of your personal information that we collect or maintain, subject to certain exceptions. For example, if we are required by law to retain the information that you are asking to be deleted, we would not be able to delete the information until we are legally permitted to delete it.
• Right to Correct. You have the right to correct inaccurate personal information that we collect or maintain.
• Right to Opt Out of Sale/Sharing. You have the right to opt out of the sale or sharing of your personal information to third parties.
• Right to Non-Discrimination. You have the right to not receive discriminatory treatment if and when you exercise your privacy rights under the CPRA.
• Right to Limit Use of Sensitive Personal Information. You have the right to limit the use of your sensitive personal information when such use goes beyond that which is necessary for providing the Services or certain other permissible purposes like fraud, customer service or quality control. Sensitive information includes Social Security number, driver’s license number, biometric information, precise geolocation, and racial and ethnic origin. However, Sumdog does not process sensitive personal information in a manner which gives rise to this right. 
  
  

If you are a California resident and wish to exercise your privacy rights, you may submit a request to our Data Protection Officer via email at privacy@sumdog.com or call toll-free 877-978-6364. Please indicate your state of residence upon submission of your request. You may opt in or out of non-essential cookies at any time by using the toggles in Your Privacy Rights.

For requests submitted via telephone, you must provide us with sufficient information that allows us to reasonably verify you are the person about whom we collected the personal information and describe your request with sufficient detail to allow us to properly evaluate and respond to it. In doing so, we will take steps to verify your request by matching information provided by you with the information we have in our records. If we are not able to verify your identity for access and deletion requests with the information provided, we may ask you for additional pieces of information. If you are a parent or guardian and are inquiring about your child, we will ask you to confirm the name of the child as it appears on the account. If you are an educator, we will ask you for your school name, school zip code, and your role. 

Only you, or a person that you authorize to act on your behalf may make a request related to your personal information. If you are an authorized agent making a request on behalf of another individual, you must provide us with signed documentation that you are authorized to act on behalf of that individual.

We will try to act on your request within one month or quicker if local law requires. You will be notified of receipt of your request within 10 days. Occasionally it could take us longer than month if your request is particular complex or you have made a number of requests.  In this case, we will notify you and keep you updated.  

RIGHTS OF NEVADA RESIDENTS

If you are a consumer in the State of Nevada, you may request to opt-out of the current or future sale of certain of your personal information. We do not currently sell any of your personal information under Nevada law, nor do we plan to do so in the future. However, you can submit a request to opt-out of future sales, as defined by Nevada law, by contacting us at privacy@sumdog.com. Please include “Opt-Out Request Under Nevada Law” in the subject line and body of your message.

DO NOT TRACK

We do not respond to Do Not Track requests. Do Not Track is a preference you can set in your web browser to inform websites and mobile applications that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

INFORMATION SECURITY 

We implement appropriate technical and organizational security measures, such as access controls and encryption, to protect the personal information that we collect and maintain from unauthorized access, destruction, use, modification, or disclosure. Additional measures include firewalls, muti-factor authentication, malware protection, regular staff training, audits, physical access controls, and robust incident response procedures. However, no security measure or modality of data transmission is 100% secure, and we are unable to guarantee the absolute security of the personal information we have collected from you.

CHANGES TO THIS PRIVACY NOTICE

We may amend this Privacy Notice in our sole discretion at any time. If we do, we will post the changes to this page, and will indicate the date the changes go into effect. We encourage you to review our Privacy Notice to stay informed. If we make changes that materially affect your privacy rights, we will notify you by prominent posting on the Websites and/or via email, and obtain your consent, if required.

CONTACT US 

If you have any questions about this Privacy Notice or need to access this Privacy Notice in an alternative format due to having a disability, please contact us via email at privacy@sumdog.com. Alternatively, please write to Sumdog Inc, 1115 Broadway, 12th Floor, New York, NY 10010 or call 877-978-6364.