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VitalSource Technologies, Inc. Privacy & Cookies Policy

This Privacy & Cookies Policy explains VitalSource Technologies, Inc.’s (“VitalSource,” also “we,” “our,” and “us”) information practices related to any of our websites (such as www.vitalsource.com) or any VitalSource owned web retail store and our products known as Bookshelf, Bookshelf Online, Bookshelf mobile applications, reader software, digital content and other products controlled or owned by VitalSource (the “Products”). You agree to the terms of this Privacy & Cookies Policy when you access or use any of the Products or websites, or take other actions described below.

VitalSource complies with the U.S. - E.U. Safe Harbor Framework and U.S. - Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland. VitalSource has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view VitalSource’s certification, please visit https://www.export.gov/safeharbor/.

VitalSource is a member of the VeraSafe™ EU Safe Harbor Program, meaning that VeraSafe has assessed VitalSource’s data governance for compliance with the VeraSafe Website Privacy Program Criteria. The program criteria require that participants maintain a high standard for data privacy and implement specific best practices pertaining to notice, choice, access, data integrity, security, and third party information sharing.

VeraSafe helps businesses protect the security and privacy of your personal information. However, if a privacy complaint or dispute cannot be resolved through VitalSource’s internal process, VitalSource has agreed to participate in the VeraSafe EU Safe Harbor Dispute Resolution Procedure for U.S. - EU and U.S. - Swiss Safe Harbor disputes. To file a complaint with the Procedure, please submit the required information to VeraSafe here: https://www.verasafe.com/dispute-submission

Information VitalSource collects about you

VitalSource collects information from you when you download, access or use any of the Products, register with VitalSource, create a user account for our Bookshelf e-reader or visit any of our websites, as described further below. This information falls into two categories: personal data and non-personal data (collectively “Information”).

Personal data includes information that identifies you specifically or from which you are reasonably identifiable. The types of personal data we collect may include your name, address, email address, phone number, other contact information, employer, academic institution, course information, and credit or debit card numbers.

Non-personal data is anonymous data that does not identify you specifically, such as aggregate data about the number of people who have accessed a particular Product.

You can choose not to provide personal data we may request of you, but, in general, most of the personal data we request is required in order to provide our service and the lack of such personal data will prevent us from doing so. We will collect, use, transfer and disclose your personal data only in ways that are consistent with this Privacy & Cookies Policy, but we may collect, use, transfer and disclose non-personal data for any lawful purpose.

We collect personal data directly from you as well as from third parties including public sources, our related companies, your organization, your representatives, information service providers, social media and the parties with whom we exchange Information as described here.

Product Registration and User Forms

VitalSource will collect Information from you when you register for an account to use any of the Products or fill out related user forms. This Information will provide basic contact data to VitalSource and enable VitalSource to deliver the correct Products to you.

Using the Products and making purchases

VitalSource also collects Information as you use the Products, make Product purchases and interact with us. This Information includes, but is not limited to:

  • facts about your purchases,
  • how you use the Products,
  • the specific Products you use,
  • the specific parts of the Products you use,
  • any notes you make in the Products or other information you input into the Products while using them,
  • analytical data created when you view the Products, create new notes, or view previous notes on any device,
  • information about page views, page usage, time on page, and other information about usage, and
  • records of any contact we have with you by telephone, email or online.

Cookies

VitalSource may collect Information about you when you visit the VitalSource website through the use of “cookies.” Cookies are small text files placed in visitors’ computers to store their preferences. Cookies themselves do not contain any personal data but may be used by VitalSource in conjunction with your personal data. A number of cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to our website and will last for longer. VitalSource may use cookies and other methods to determine your domain name and what browser and operating system you are using, your Internet Protocol (IP) address, the date and time of your request if any, and the device you are using.

We use cookies to:

  • remember that you have visited our website before; this means we can identify the number of unique visitors we receive. This allows us to make sure we have enough capacity for the number of users that we get;
  • customize elements of the promotional layout and/or content of the pages of our website;
  • collect anonymous statistical information about how you use our website (including how long you spend on the website) and where you have come to our website from, so that we can improve the website and learn which parts of it are most popular with visitors; and
  • gather information about the pages on our website that you visit, and also other information about other websites that you visit, so as to place you in a “market segment”. This information includes information about the county and city you are in, together with the name of your Internet service provider. This information is then used to place interest-based advertisements on our website which it is believed will be relevant to your market segment. For more information about this type of interest based advertising, and about how to turn this feature off please visit www.youronlinechoices.com and www.youronlinechoices.com.au.

Some of the cookies used by our website are set by us, and some are set by third parties who are delivering services on our behalf.

Our cookies
Cookie name Purpose Type and duration
[i.e. session only or persistent]
Persistent Cookie Saves user information that may be accessed every time a user visits our site. Persistent – outlasts session duration.
Session Cookie Saves user information that may be accessed only as long as the browser session exists. Session – lasts only as long as the session duration.
Third Party These cookies save information on the user’s computer and are accessed from domains different from the one shown in the address bar. Persistent – outlasts session duration.

In addition to cookies, tracking GIFs may be set by us or third parties in respect of your use of our website. Tracking GIFs are small image files within the content of our website or the body of our newsletters so we, or third parties, can understand which parts of the website are visited and whether particular content is of interest.

Most web browsers automatically accept cookies but all computers have the ability to decline cookies. This can be done by activating the setting on your browser that enables you to decline the cookies. Please note that if you choose to decline cookies, you may be unable to access parts of our website. You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browsers.

VitalSource’s use of your Information

VitalSource uses your Information, by itself or in conjunction with data lawfully collected through other sources, for the following purposes:

  • to meet our contractual commitments to you,
  • to administer your account and respond to your requests,
  • to provide the Products requested by you, including to provide the correct Products requested for your selected computer or device,
  • to maintain and improve the Products and to develop new Products,
  • to track your purchase history and to provide you on an ongoing basis with information related to the Products, including changes to the Products or other information we think you may find useful about our products and services or those of carefully selected third parties, provided you have indicated that you do not object to being contacted for these purposes,
  • to customize content supplied to you,
  • to conduct research and to update our website and analyze how it is used,
  • to prevent, investigate and deal with fraud, violation of intellectual property rights and other laws and unauthorized use of Products or your account, and
  • as otherwise reasonable and appropriate to the legitimate business needs of VitalSource related to the Products.

You can tell us not to contact you with information regarding our products and services and those of third parties, either at the point your personal data is requested on our website (by checking or un-checking (as directed) the relevant box) or, where you do not wish us to continue to use your personal data in this way, by following the unsubscribe instructions on any communications sent to you. You can also exercise the right at any time by contacting us using the Contacting us details at the end of this Privacy & Cookies Policy.

Sharing your Information with third parties

VitalSource appreciates that you do not want your personal data distributed indiscriminately and we agree not to sell or share this information except as described in this Privacy & Cookies Policy. We may exchange your Information with the parties described below.

Academic Institutions. You acknowledge that, where the cost of any Product(s) that would otherwise need to be paid for is covered by the academic or other institution through whom you are studying and you are given a code to redeem for the relevant Product(s) (instead of having to pay yourself), that institution may, as a condition of your being provided with the Product(s) free of charge to you, have agreed with us that VitalSource must share Information related to your use of the relevant Product(s) with the institution. Your institution may wish to see, for example, that you have accessed and used a certain Product or certain of its contents, or spent a certain amount of time using it. This Information may be used to help your institution evaluate your progress and improve your learning. By using one of these codes, you agree to VitalSource sharing usage Information with your institution in this way.

Content Owners. VitalSource may share non-personal data about you and your use of the Products with content owners or licensees that have rights related to the Products that you access (“Content Owners”). Content Owners will use this non-personal data for their own research and tracking purposes, to evaluate Product use and access, to improve Products and related analysis. VitalSource will not reveal your personal data to Content Owners, just anonymous Product usage data that does not identify you specifically.

Third Parties and Affiliates Performing Support Functions. VitalSource may exchange your Information with third-party service providers and with VitalSource affiliates (such as parent companies, subsidiaries, or other companies within our corporate family) that perform support functions related to the Products. The purpose of this sharing may include research, analyzing usage data, providing marketing assistance to VitalSource, processing your credit or debit card payments, providing customer service to you, processing and fulfilling your orders, providing you with Product access, for storage, assisting VitalSource with providing the Products to you, assisting VitalSource in using the Information as described in this Privacy & Cookies Policy, and related matters.

Disclosures As Required By Law Or To Prevent Harm. VitalSource reserves the right to exchange Information with relevant parties such as courts, government agencies and lawyers if it reasonably believes that collection, access, use, preservation or disclosure of such Information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process, or enforceable governmental request, (b) enforce applicable terms of use, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address illegal or suspected illegal activities, security or technical issues, or (d) protect against harm to the rights, property or safety of VitalSource, its affiliates or users, the Content Owners or the public, as required or permitted by law.

Assignment of Your Information. VitalSource may exchange Information with third parties (such as purchasers, potential purchasers and their advisers) if VitalSource or a portion of its assets is sold or offered for sale. You grant VitalSource the right to transfer ownership of all Information (including personal data) that VitalSource has about you to a third party in connection with the sale of VitalSource or its assets, without payment to you. You acknowledge and agree that the third party may use your Information for the purposes described in this Privacy & Cookies Policy and related uses without payment to you.

Public forums

Some of the Products may, from time to time, make chat rooms, message boards, news groups and/or other public forums available to users. Any information that is disclosed in these areas becomes public information and you should exercise caution when using these and never disclose your personal data.

Childrens’ privacy

You must be 18 years of age or older to create a Bookshelf account. While individuals under the age of 18 may utilize the Products, they may do so only with the involvement, supervision, and approval of their parent or legal guardian. VitalSource does not solicit orders or knowingly collect Information from children under the age of 13. If we have reason to believe that any Information has been submitted to us by a child under 13, we will delete that information after taking appropriate actions to prevent further Information submission and as required by law.

Security

VitalSource takes information security very seriously and has taken reasonable measures to keep your Information secure from unauthorized access or disclosure, whether that Information is stored physically or electronically. VitalSource has established the appropriate administrative, technical, physical, electronic and managerial procedures to prevent unauthorized access, maintain data security and use the Information collected from you in accordance with this Privacy & Cookies Policy. VitalSource has security measures in place to protect against loss, misuse, or alteration of your Information. Our secure server software is among the best software systems available for secure Internet payment transactions. It encrypts your payment information to seek to ensure it is not intercepted as it travels over the Internet. Submission of Information over the Internet, however, is never entirely secure. Despite its reasonable efforts, VitalSource cannot guarantee that unauthorized access or disclosure of Information will never happen. If you have concerns, do not use the Products.

It is advisable to close your browser when you have finished your user session to help ensure others do not access your personal data if you use a shared computer or a computer in a public place.

International transfer of Information

Given that the Internet is a global environment, using the Internet to collect and process Information necessarily involves the transmission of data on an international basis. Therefore, by using any of the Products, you acknowledge and consent to the transfer of your Information outside your country of residence to any country (including the United States, Canada, the United Kingdom and Australia) where we have facilities or engage third parties (including but not limited to payment processors, cloud service or other IT providers, and other companies that provide services to us). You understand that the countries to which we may transfer Information may not have as comprehensive a level of data protection as in your country. In relation to Australia’s Privacy Act, you agree that in the case of a breach of by the third party in relation to handling your personal data, we will not be accountable for the third party under the Privacy Act and you may not be able to seek redress under the Privacy Act.

You may find links to third-party websites from any of the Products. These websites may have their own privacy and/or cookies policies, which you should check. We do not accept any responsibility or liability for their policies because we have no control over them.

Your rights

You can contact us to request access to, correction, or erasure of the personal data about you held by us, or to raise any concerns about our handling of that data.

You have a right to request a copy of all the personal data about you held by us. On request, we will provide you with a copy of this personal data. You also have a right to correct any errors in that personal data.

In the case of access and correction requests, please provide as much detail as you can about the particular data you seek, in order to help us locate it. We will provide our reasons if we deny any request for access to or correction of personal data. Where we decide not to make a requested correction to your personal data and you disagree, you may ask us to make a note of your requested correction with the data.

We take your privacy concerns seriously. Where you express any concerns that we have interfered with your privacy, we will respond to let you know who will be handling your matter and when you can expect a further response. We may request additional details from you regarding your concerns, and may need to engage or consult with other parties in order to investigate and deal with your issue. We will keep records of your request and any resolution.

As mentioned above, you have a right to prevent the use of your personal data for direct marketing purposes.

Changes to this Privacy & Cookies Policy

The information practices described in this Privacy & Cookies Policy are current as of the effective date at the end of this document. VitalSource reserves the right to periodically update this Privacy & Cookies Policy at its discretion. Notice of any revisions will be posted to this page and are effective once posted. If you are concerned about how your Information is used, bookmark this page and check back periodically.

Contacting us

If you have any questions, comments, or requests regarding this Privacy & Cookies Policy, including the treatment of your personal data and/or our use of cookies and other technologies, please contact us by mail or email using the following contact information:


 Vital Source Technologies, Inc.

234 Fayetteville Street Suite 300
Raleigh, NC 27601

privacy@vitalsource.com

Effective and last updated April 16, 2015.