We are committed to safeguarding the privacy of our website visitors. This policy sets out how we will treat your personal information.
(1) PERSONAL INFORMATION WE COLLECT
We may collect, store and use the following kinds of personal information:
(a) User account data:
Information collected to create and administer your VentureBlocks account. This includes your name, email, organization, and password which you use to log into your account. This also includes information about your use of VentureBlocks, including simulations played, including score, level, status, and all other attributes of our simulations. This also includes information relating to any transactions carried out between you and us on or in relation to this website, including information relating to any purchases you make of our goods or services such as order numbers, costs, bills, and invoices (we do not store credit card numbers; these are directly processed by Stripe).
We use Elastic Email to manage the sending of emails from VentureBlocks. We share your name, email, and the contents of emails sent by VentureBlocks with this provider, because it is necessary to manage the proper sending of emails in addition to opt-out lists.
(b) Usage and security data:
Information collected to maintain security for our users, perform audits of our system and security procedure, identify suspicious behavior, and implement additional security measures as needed. This information includes login credentials: your email, username, and password, in addition to your IP address. This may be linked to your VentureBlocks account. Finally, we may also collect information about your computer and browser, including browser type and version, operating system, and other technical details as needed to diagnose and identify bugs, as well as to provide technical support to users.
We also collect information about crashes and bugs in our simulation software, which is automated and built into our simulation software (including code information, your simulation information, and a visual representation of the simulation you were playing at the time of a crash or bug; we do not capture screenshots of your whole screen, but rather a rendering of the simulation screen that you see in your browser window, and nothing else from the browser window, at the time of a bug)
We also collection information about email send times, content, opens, and clicks. This information is used to track whether emails are being delivered, and to inform professors if their students never received emails to sign up, or if emails did not go through.
(c) Analytics data:
Information collected to understand trends and website usage patterns. This includes information about your visits to and use of this website including your geographical location, browser type and version, operating system, referral source, length of visit, page views, website navigation and details. We use Google Analytics to analyse the use of this website, and request that your IP be anonymized before being used for any reports provided to us.
(d) Sales and marketing data:
Information collected to contact potential users for the purposes of sales and marketing. Instructors and partners who provide their email on ventureblocks.com may receive occasional emails from us regarding how to use our system and the benefits of becoming a customer.
(e) Log data:
We automatically collect information about your computer hardware and software when you use our services or view our content. This information can include your IP address, browser name and type, operating system, domain names, Internet Service Provider (ISP), the files, images, videos, and content viewed on our website as well as when they were viewed, and referring website addresses. We collect this information for security purposes, and to be able to debug a serious malfunction of the website. We do not associate log data with the personal information of our users, such as name, email, or address, unless there has been a security breach or incident in which case we may do so to the extent allowed by law.
(f) Payment data:
We collect your payment information in the event that you choose to purchase our software. We need this information to process a payment from you. Such information includes your credit card details (name, number, expiration, code, address, etc) or your bank information in the event that you send us a wire transfer. This information is not stored by us, but rather by Stripe, our payment processor, or Bank of America, our bank. We may, however, store invoices, which include personal information such as your name and contact information, along with purchase defailt such as total cost and the number of purchased licenses. Invoices are stored securely on our server or on a business computer, both located in the United States.
(g) any other information that you choose to send to us
A cookie consists of information sent by a web server to a web browser, and stored by the browser. The information is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser.
We use "session" cookies and "persistent" cookies on the website. We will use the session cookies to: keep track of you whilst you navigate the website. While we do not use persistent cookies, our Data Processor Google Analytics does. They do this for the purpose of recognizing you when you visit; and other uses.
We have set up Google Analytics to only collect anonymous information about you (and your IP address is randomized for the reports they provide us), with the intention of not collecting any personally-identifiable information about users.
Most browsers allow you to reject all cookies, whilst some browsers allow you to reject just third party cookies. For example, in Internet Explorer you can refuse all cookies by clicking "Tools", "Internet Options", "Privacy", and selecting "Block all cookies" using the sliding selector. Blocking all cookies will, however, have a negative impact upon the usability of many websites, including this one.
(3) HOW YOUR PERSONAL INFORMATION IS USED
We may use your personal information to:
(a) administer the website
(b) improve your browsing experience by personalising the website
(c) enable your use of the services available on the website
(d) send to you goods purchased via the website, and supply to you services purchased via the website
(e) send statements, invoices, and receipts to you, and collect payments from you
(f) send you general (non-marketing) commercial communications
(g) send you email notifications which you have specifically requested
(h) send to you our newsletter and other marketing communications relating to our business which we think may be of interest to you by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications)
(j) deal with inquiries and complaints made by or about you relating to the website
(k) debug our software in the event of a bug or any code changes
(l) to process payments from you
(m) other uses
Where you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the license you grant to us.
In the event that you signed up for VentureBlocks through one of our partners, your personal information will be shared with that partner. You agree not to hold VentureBlocks LLC responsible for the actions of partners and their usage of your personal information.
Our simulation uses bug tracking software that notifies us of bugs and crashes. This notifies us of code issues, as well as details of your simulation, including but not limited to code being executed and a screen capture of your simulation window (only the simulation, nothing else in your browser or computer). We may use this to provide technical support to you, or notify you of a bug.
Your personal information is stored indefinitely, which is necessary to keep your account active and working. You may request a copy of or deletion of all your personal information by contacting us at email@example.com. This is not limited to users in the E.U. per GDPR regulations, but is rather available to all users.
(4) DISCLOSURES AND SHARING OF YOUR PERSONAL INFORMATION
In addition, we may disclose your personal information:
(a) to the extent that we are required to do so by law
(b) in connection with any legal proceedings or prospective legal proceedings
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk)
(d) to the purchaser (or prospective purchaser) of any business or asset which we are (or are contemplating) selling
(e) to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information
The website has the following Data Processors with whom personal information may be shared:
- Google Analytics, for the purpose of analyzing user trends. We make every effort not to share any of your personally identifiable information with this Data Processor.
- Google Mail (Gmail), for sending and receiving electronic communications to/from customers and partners. Your name and email address is shared with this Data Processor for the purpose of communicating with you.
- Elastic Email, for managing the automated sending of electronic communications from the website. This includes notification emails, password resets, account and billing related emails, and other emails sent as a result of actions you take while using the website, or to notify you. We also use this Data Processor for marketing emails for instructor accounts and demo requests received on our website.
We reserve the right to publish anonymous aggregate information about our users, which does not contain any personally identifiable information. For example, information such as "5,000 students used VentureBlocks this month" or "90% of students reach level 8 when playing". We may also publish aggregate information (not individual information) for other users playing the same simulation as you. For example, information such as "your classmates most frequently ask leading questions".
For student accounts, the instructor who added you to their simulation is able to see your name, email or username, whether you have an active license, whether you have played the simulation, an estimate of time spent playing, your current and high scores, your level, debrief question answers, notes taken, and other details of your simulation and gameplay. If your student account has a username instead of an email, and your password is managed by your instructor, they are able to see your password (this does not apply to users who use email to sign in). For student accounts, we will not disclose your information to other users of the website except for (a) the instructor who created your simulation ("your instructor"), and (b) any instructors or users for whom your instructor explicitly requested we grant access to your simulation analytics data (for example, if there are program administrators or co-instructors who your instructor wants to have access to your information). We may provide your instructor with additional simulation information upon your instructor's request. We may also provide information about your license to a partner account if that partner account is associated with your purchase of a license. This information will not include your name and contact information but rather information specific to your license, such as whether it was purchased, when it was purchased, whether it was activated, when it was activated, and other information. Partner accounts may include retail stores, online stores, publishers, and other VentureBlocks users who may resell VentureBlocks licenses.
For instructor accounts, when you add a student to your simulation, we send them your name by email, along with your course name, course section, and course number so that they are able to identify the purpose of the email. If an instructor or partner account transfers licenses to another instructor or partner account, the first and last name of the user who initiated the transfer is shared with the recipient, and the email of the recipient (which was entered by the sender) is sent to the sender in an email confirmation. If you use the feature that allows you to post a registration link (URL) for students, anyone with access to the URL will be able to view your name, along with your course name, course section, and course number so that they are aware of the course they are registering for; in this case we do not guarantee the privacy of this URL and this personal information because it is up to you to keep it private. We may also provide information about licenses purchased by you to a partner account if that partner account is associated with your purchase of a license. This information will not include your name and contact information but rather information specific to your licenses, such as when they were purchased, whether they were assigned to students, whether they were activated, when they were activated, and other information. This information may also include a count of license information by instructor, for example to report to a partner how many instructors and students are using licenses sold by that partner. In this case your personal information is not shared and the existence of your account is used in a tally. Partner accounts may include retail stores, online stores, publishers, and other VentureBlocks users who may resell VentureBlocks licenses. We will not disclose your information to other users of the website, including other instructors, and also students (except for the aforementioned situations).
(5) SECURITY OF YOUR PERSONAL INFORMATION
We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
We will store all the personal information you provide on our secure (password- and firewall- protected) servers. All electronic transactions you make to or receive from us will be encrypted using SSL technology, with the possible exception of email as some email services do not use SSL and we do not have control over this.
Of course, data transmission over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
You are responsible for keeping your password and user details confidential. We will not ask you for your password (except when you log in to the website or app).
(6) LEGAL BASIS FOR COLLECTING AND PROCESSING YOUR PERSONAL INFORMATION (EEA VISITORS/USERS ONLY) UNDER GDPR
If you are a visitor or user located in the European Economic Area (EEA), or if you a citizen of a country in the EEA, VentureBlocks LLC is both your Data Controller and Data Processor, though we have other Data Processors including Amazon Web Services and Google Analytics. Please see the bottom of this page for contact information for our Data Protection Officer.
Our legal basis for collecting, processing, and otherwise using the personal information described on this page depends on the specific personal information in question and the context in which we collect it. However, we will normally collect personal information from you only where we have consent to do so, where we require the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.
(7) REVIEWING, UPDATING, AND REMOVING YOUR PERSONAL INFORMATION UNDER GDPR
You have the following GDPR data protection rights:
(a) You may request us to provide you with any personal information we hold about you.
(b) You may request us to update any personal information we hold about you.
(c) You may object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
(d) If the personal information we have collected about you was collected with your consent, you may withdraw your consent at any time. Doing so will not affect the lawfully of any data collection or processing prior to when consent was withdrawn, and it will not affect the processing of your personal information on other legal grounds than consent.
(e) You may request we delete your personal information from our system. We agree to destroy the email/student information at the request of any user who is either:
a student, or
an instructor at an accredited school or university, provided that user purchased licenses for its student users (if students purchased their own licenses, this does not apply).
Deleting personal information will immediately invalidate all licenses for students whose information is destroyed and they will no longer have access to any part of the website services. No refund will be provided for destroyed data. Destroying data will not destroy it from our data backups; we retain secure daily backups of all user data, which cannot be altered, and therefore student data cannot be destroyed from backups until the backups themselves are destroyed. For this reasons the deletion of personal information from our systems and backups will take us 30 days.
You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. In some cases our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.
(8) FOR EU AND SWISS INDIVIDUALS: PRIVACY SHIELD NOTICE FOR PERSONAL DATA TRANSFERS TO THE UNITED STATES.
Your personal information and all data collected from you is stored on servers hosted by Amazon Web Services. These servers are located in the United States. Backups of your personal information may also be stored on computers based in the United States. This is necessary for testing and the development of new features. Access to all data is restricted and limited to members of VentureBlocks LLC.
The Federal Trade Commission has jurisdiction over VentureBlocks LLC compliance with the Privacy Shield.
Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also may correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to firstname.lastname@example.org. If requested to remove data, we will respond within a reasonable timeframe.
We will provide an individual opt-out or opt-in choice before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to email@example.com.
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
In the context of an onward transfer, VentureBlocks LLC has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. The Privacy Shield organization shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless the organization proves that it is not responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, VentureBlocks LLC commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact VentureBlocks LLC at:
Attn: Privacy Officer
101 Hull Street Suite 1
Belmont MA, 02478
VentureBlocks LLC has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction
(9) THIRD PARTY WEBSITES
The website contains links to other websites. We are not responsible for the privacy policies or practices of third party websites.
(10) POLICY AMENDMENTS
(11) CONTACT INFORMATION
Attn: Anton Yakushin
101 Hull Street Suite 1
Belmont MA, 02478
GDPR Data Protection Officer:
Attn: Anton Yakushin
101 Hull Street Suite 1
Belmont MA, 02478