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Welcome to 21 Money IQ™
Last updated August 2024
This Privacy Notice (“Notice”) describes how 21 Money IQ™, LLC., (“we,” “us,” “our”) an online platform for education and engagement, collects, uses, and otherwise processes your personal information. This Notice addresses our practices, including the types of personal information, individuals, activities, and third parties.
This Notice applies to the information that we process including what we do with personal information that is provided to us by individuals and organizations with whom we partner, such as learners, parents, schools, non-profit organizations, employers, and/or users. However, we can only tell you what we do with the personal information, not what any other organization does unless they are our vendor, hired to process data according to our instructions.
Please also keep in mind that our Site and applications may contain links to other sites not owned or controlled by us and we are not responsible for the privacy practices of those sites. We encourage you to be aware when you leave our Site or applications and to read the privacy notices of other sites that may collect your personal information.
We may change this Notice at any time and will include the last date it was updated. If necessary or there are material changes, we will provide notice or obtain consent regarding such changes if required by law.
Please review the sections below and if you have any questions, please do not hesitate to contact us at info@21moneyiq.com under the subject: Privacy.
Key Terms
We use some key terms in our Notice that you should know as you read the information.
Customers include Learners, their Parents and/or School Personnel, and Partners
Learners are the minors (18 years and younger) who are enrolled and/or participate in the 21 Money IQ™ Site
Parents and/or School personnel are the parents or legal guardians of Learners, and/or School personnel partnering with our services
Partners are companies (third parties) that we work with, technology vendors, and community businesses or members
Services means the online curriculum, student workbook, or other engagement by members with our Site
Online Curriculum means the lessons developed and available on our Site
Student Workbookmeans the color-printed follow-up activities to each lesson that complement our Site services
Personal Information/Datameans information linked to an identified (or identifiable) individual
Process means any activity with personal information, e.g., collecting, using, sharing, storing, etc.
Your Personal Information
Website Visitors and General Consumers (anyone)
We collect information through technology for website visitors who do not engage with us directly. If you interact on our website, we will track your activities online, but we do not know who you are.
However, if you submit a form with your contact information, we will engage with you as requested and may follow up with you to further build a relationship, generally through communications and marketing (see below). You can opt out of marketing communications at any time.
How do we collect this information? You typically provide this information voluntarily.
Why do we collect this information? We respond or initiate communications in provision of Site changes or in response to a request. This is based on the requirement to provide you services or our legitimate interest to grow our business and understand our Customers and their needs better. Our legitimate interest in this relates to sending you the request, in which you may choose to respond or not and can choose to ask us not to contact you for those purposes. Given this, our legitimate interest is not outweighed by the risk to you.
Communication
When you communicate with us, regardless of the channel, we keep records of communications and act on them as appropriate, whether email, messaging, or other forms of communication. Communications may be managed by various departments and/or third parties, including Trust & Safety or Legal. We may also communicate with you to better understand our market, and ask you to participate in study groups, surveys, video interviews, etc. We will provide more information to you at the time.
Social Media
We may interact with you using social media in a variety of ways. We may “follow” you or ask you to “follow” us. We may create groups on social media for interaction. We may ask for your social media handles or tags to use in advertising. We may copy your posts or statements and follow up internally or with you.
Marketing
We will use your contact information to communicate with you unless you instruct otherwise. We do not collect Learner information for marketing purposes. We may obtain information from third parties, such as matching your email address to a publicly available physical address and sending physical marketing materials, like postcards. You can request that your email or other information in your profile not be used for marketing purposes. If you opt out of marketing emails, we will continue to send emails related to our services and respond to any requests from you. Please contact info@21moneyiq.com for questions using the subject: Marketing Question
Individuals with Third Parties
If you work for (or are with) a Partner, vendor, or other third party, we engage with you as required for the relationship to build, maintain, and terminate. We will only process your business-related information in furtherance of our relationship and engagement in the potential or actual relationship, such as payments, contracts, and via technology. You may also engage with us as a member of the general public as described above or as a Customer described below.
Customers (Learners, Parents, and Partners)
The personal information we process can be grouped into three main categories: information you (or your learner) provide to us, information we get from third parties about you, and information we get from cookies and trackers. These are the three categories (you can find more details below):
1. Information you provide to us
Account, Services, and Finances
Sensitive Information
2. Information we get through third parties (such as partners or via social media); and
3. Information we get through technology, including device info, cookies, and trackers[1].
4. Inferred and Combined data
1. Information you provide to us
For engaging with us, you provide us information directly for your Account, Services, and Finance. More detail is provided below for each one of these, but here we explain how and why we process this information.
How do we collect this information? If you engage with us directly, we collect this information from you or from linked accounts (like Google or Facebook logins) that you choose to share the data with us. You also volunteer information when you complete parts of your profile. You can choose not to provide this information. If you come to us through a partner, some of the data comes from them, but some is provided by you when you complete the registration. If you are a Learner, your Parent or School personnel may provide your information. When engaged with classes or activities, participants may be requested to submit some information to complete the assignment and some information is volunteered through your engagement, like comments or feedback.
Why do we collect this information? We collect these data to add you to our platform and let you engage with us - generally at your request or consent, which you may revoke at any time. Revoking consent may end your enrollment or account, depending on your request. You can participate without providing any voluntary information, but you must provide required information. We may also use information provided to us to prevent fraud. In general, we use your information to provide the Services, customer support, and to improve our platform and Services.
1.1 Account Information
When you join 21 Money IQ™, we ask for your name or publicly posted name from a linked account (such as Facebook, Google or Apple), email address, phone number, and postal address. We collect information about the Activities you can or wish to be involved with (as Learner, Parent, or School Personnel) and keep a history of your Activities. You may choose to provide additional information in your profile, such as age, gender, pronouns, title, and profile photo. To activate your account, Learners require a contract to be in place.
1.2 Services
We collect information about access to lessons, completion of lesson quizzes, delivered color-printed student workbooks with which you or a Learner engages, purchase and delivery of products, and the history of activity in and with 21 Money IQ™. We may want to assess if certain parts of the website or Services work better than others and if so, may present one version to some group (of Customers, general consumers, etc.) and one to another. There is no substantive difference between the options. We do this to better determine how to design our site for engagement.
1.3 Finances
For purchases, we collect name, credit card or other payment information, billing address, and information about the Services purchased. For payments to you, we collect your financial account information if necessary, payment details, and information about our payments, such as the reason or history. We also use financial information to detect or prevent fraud.
1.4 Sensitive Data
“Sensitive data” has different meanings depending on location. Where possible, we apply heightened protection to sensitive data. In some places, information from a child may be considered sensitive information itself. You or a Learner may voluntarily provide sensitive information, such as health or disability information included in forms, messages, or with a complaint or concern. Learners, Parents, School personnel, and/or the public are not allowed to have discussions that may elicit or result in sharing of sensitive information, and where they do learn sensitive information, they are not permitted to share that outside 21 Money IQ™ or use it in an inappropriate way.
2. Information we get through Third Parties
We may get information on you from Customers, Partners, third parties or vendors on Customers or potential Customers. This may include us getting the information directly or it may be getting your information from Partners. More detail is provided below for each one of these, but here we explain how and why we process this information.
How? We get information from third parties either by purchasing or leasing it, indirectly through our own vendors, or by engaging with you through third parties, like social media (see Social Media above). Also, our current Customers may share information in our referral program. We do not buy or lease information from third parties on Learners.
Why? In most cases, we obtain or purchase data so we can grow our business - so this is in our legitimate interests as a business to do so. We may use these data to report suspicious activity to a local agency. If so, this is either for addressing fraud or for the safety of Learners.
Information from Partners. 21 Money IQ™ partners with other organizations, such as schools, non-profits, and employers to provide services. In general, these Partners would provide your information to us for you to access our Site in which they may have some control over parts of the platform (such as schools) or where they are offering the Services to you as a joint effort. Partners will likely provide you with specific information when the relationship is set up, especially if they have some control over parts of the platform. If so, you need to look at their privacy notice for how they manage your information.
We also partner with technology companies to jointly provide some services. In some cases, you need to create an account with the partner to use their services and when you link your account there with your account with us, they may provide information to us.
Information from Vendors. At times, we may purchase (or lease) data from third parties for certain reasons. We don’t know how these third parties get your data, but it is generally through advertising services or other companies you have used who are able to share your information. We do not sell that information, but we may share it with our vendors, such as if we buy a mailing list of parents in a certain area, we will share those addresses with a vendor who may print and mail the postcards. The data we get may be just on a group of people where we provide characteristics we want or we may provide the names (not on Learners) to get more information on them, such as addresses for marketing materials or for reporting an event to the local agencies.
Information from other third parties. At times, you may decide to login to our services using a linked account, such as Facebook or Google. We make sure that you are able to do this, but it does mean you may be providing us with more information about you. You should check the privacy notices of these providers to see what they share with us. We may also get information through third parties if you access them on our Site. In good faith, we try to control the use of third-party tools, but we may not succeed every time.
3. Information we get through Technology
Some data we get through technology, such as cookies and trackers on the website. We do not knowingly track data on minors. More detail is provided below for each one of these, but here we explain how and why we process this information.
How do we collect this information? These data are collected through technology. This means simply by coming to our website or using our app, you are providing certain information automatically. Some of these you can opt out through your computer or browser settings, but others are necessary.
Why do we collect this information? More details are below, but some data are necessary for the operations of the website and app, and some are optional. Optional reasons include analytics, preferences as discussed above about testing certain features or preferences on our site, assessing user behavior and tech problems, along with other useful information. Unless it is necessary for the website or app to work, our reasons are linked to our legitimate interests in having this information that we do not believe impact your rights and freedoms. This information also helps us personalize your experience with us. It also helps us detect and investigate fraud and violations of our policies.
Technical, Device, and Usage Data: This is information that we automatically collect about your device and connection when you engage with 21 Money IQ™ and it includes your IP address, device identifiers such as cookie identifiers and mobile device identifiers, operating system type, and the type of browser. This may include data about your usage (such as login times, search terms , items you click on, error messages, and pages you viewed) and location data. We do not collect data from third-party ad trackers on Learners.
4. Inferred and Combined Data
We provided information on how and why we collect and process your information and provided a lot of information about the sources of information and the purposes for which we use your information. However, you need to know that using your information is not always so straightforward, we infer information about you, and we combine data to have a more complete understanding of you.
Inferred Data: We may infer new information from other data we collect to generate information about your interests. We may also infer your general geographic location (such as city, state, and country) based on your IP address.
Combined Data: We may obtain information from you from sources other than you, such as through partners, employers, third parties, or social media. For example, you may have accounts through your school or employer, and also directly. Where possible, we combine these sources to have one extensive view of individuals engaged with 21 Money IQ™.
As we explained in the sections above, we may use any of the above categories of your personal data to:
Provide services to Customers, Partners, third parties, and employees;
Perform our business operations;
Manage our relationship with Teachers, Parents, and other individuals.
Sharing Your Data
We may disclose your personal data to the following categories of third parties:
Other Customers: Members of a class may be able to see, hear, and read the interactions with the other members. This may include other Parents, Learners, and other individuals that any member of the activity or class requires in order to participate, such as an interpreter. However, no one should have other individuals involved in class that should not be there for a legitimate and pre-approved purpose. 21 Money IQ™ prohibits non-approved people on our site engaging with Learners or other Customers.
Partners: Where we work with organizations (schools, employers, non-profits, tech companies, etc.) that provide opportunities or funding to you for Services, we will share information back to them about Learner engagement. As mentioned above, you will be aware of these engagements as generally, that is how you came to 21 Money IQ™ or used their codes / vouchers to pay for Services or you specifically connected your account with them to us.
Vendors/Service Providers: We engage third-party service providers to perform certain activities on our behalf, such as hosting (AWS), communications (e.g., Google, Intercom), marketing (e.g., Postmark), analytics, payment processing (e.g., Swipe, PayPal, Afterpay), video hosting (Zoom), and website maintenance. This is not a complete list, but a sample of some third parties we may use.
Business Transactions: If we engage in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be transferred to a successor or affiliate alone or as part of that transaction along with other assets. This may occur before the transaction is complete as part of the transition or evaluation, although where possible, we will ensure the other entity honors the privacy protections.
Legal Requirements: We may disclose your personal data if required to do so by law or when we believe that such action is necessary to (i) comply with a legal obligation or a request from someone with legal authority to do so, (ii) protect and defend the rights or property of us or those of Customers or Partners, (iii) operate and maintain appropriate security, including to prevent or stop an attack on our computer systems or networks, (iv) to protect the personal safety of Customers or the public, or (v) protect against legal liability.
Third-Party Analytics and Advertising Companies: We allow third-party analytics and advertising vendors to collect personal information, including the Technical Data described above, data about your usage, and inferences about you based on such data. Except for data collected from Learners in Learner Space, these third-party vendors may combine these data across multiple sites to improve analytics for their own purpose and others. If you reside in California, you can opt out of this processing by clicking here: Do Not Sell My Personal Information (Please also see our CA+ Supplemental Notice). We do not sell your data for money, but we may receive services or a discount in exchange for some data collected online (not Learner data). For more information about the cookies and other technologies we use and your choices regarding what personal data they collect.
Information Disclosures Requested by You: You may transmit information to third parties or request us to do so, including the general public. For example, you may voluntarily: (i) message others using 21 Money IQ™ or our team; (ii) upload personal data to your user profile which may be accessible to other users; (iii) or disclose information about yourself to other Learners. We expect everyone to respect the privacy of others, such as disclosing private material, communications or information, or disclosing other personal data about others that may cause harm, embarrassment, or conflict. Please also see our Terms of Service.
Please note that access to Site content may include references or links to or suggestions to engage with third parties whose privacy practices differ from ours. If you provide personal data to any of those third parties, or instruct us to disclose personal data to them, that data is governed by their privacy notices.
Where In The World Is Your Data?
We are located in the United States. Our third-party analytics and advertising vendors are located in the United States but may also include local vendors and support services in other countries around the world. This is not a complete list. Please contact us if you would like more information.
If transferring your data outside your country requires your consent or other transfer process, we intend to follow the requirements. In most cases, our legal reason for processing your information is to complete a contract with you, generally to provide the Services you have engaged in with us, whether free or paid or to allow you to provide Services on our platform. Please let us know if you have any questions.
Your Rights and How to Manage or Delete Your Personal Information
Where permitted under applicable law, you have the right to request access to your Personal Information, delete, change or correct your Personal Information collected by 21 Money IQ™. If you are a Parent or a Partner you can access and update the information associated with your 21 Money IQ™ account directly by logging into your 21 Money IQ™ account and viewing the Account Settings tab on your profile.
To exercise your rights mentioned above or if you are Parent/Guardian and want to correct, edit, update or delete information about your child, please contact us at info@21moneyiq.comunder the subject: Privacy. If you are a Parent/Guardian, your account deletion may impact multiple Learners and if you do not specify a specific Learner, all will be deleted. Once deleted, you will not be able to reinstate your Site access or other history, including payment. Please note that as part of your request, we may require additional information and documents, including Personal Information, in order to authenticate and validate your identity and to process your request. Such additional information will then be retained by us for legal purposes (i.e., as proof of the identity of the person submitting the request).
Contact Us
Please contact us if you have any comments or questions about this Notice or our information processing practices by emailing at info@21moneyiq.com under the subject: Privacy or mailing:
21 Money IQ™, LLC., 1718 Capitol Avenue, Cheyenne, Wyoming 82001 (“Notice Address”)
Keeping And Securing Your Data
We take steps intended to protect the personal data that we collect from loss, misuse and unauthorized access, disclosure, alteration, or destruction. However, the Internet cannot be guaranteed to be fully secure, and we cannot ensure the security of any content or information you provide to us. You are also responsible for helping to protect the security of your account credentials. For instance, never give out your password, and make sure to safeguard your username, password, and personal credentials used to access 21 Money IQ™, so that other people will not have access to your personal data. Please do not use the username and password you use with us with any other services.
We retain the information we collect for the duration of the services with you. For Parents and Learners, this is generally one year past the time you cease interacting with us, or at your request. For Teachers, local law may dictate certain retention periods for payment purposes.
[1] 21 Money IQ™ uses cookies and similar technologies to help deliver our service. Scroll to the bottom of this article for a list of cookies and other similar technologies used by the site. The list indicates the name of cookies organized by purpose and provider, as well as privacy policies and opt-out links. Please note, however, that in Learner Spaces we do not use advertising technologies, and only use analytics technologies for purposes described in our Privacy Policy.
21 MONEY IQ™
email: info@21moneyiq.com
Copyright © 2024 21 Money IQ - All Rights Reserved.
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