SOLARO™

         

Our Commitment to Your Privacy

Welcome to SOLARO.com, an online service where pre-kindergarten to grade 12 students can receive educational content, tutoring and support as well as reliable testing and assessments in a customized learning environment that will give them access to peer support and expert educational help as part of a community of learners.

The SOLARO™ service is provided by Castle Rock Research Inc. (referred to as “we”, “us” or other similar terms or “SOLARO™” in this Privacy Policy).  To better protect your privacy, we provide this Privacy Policy to explain our information practices relating to the SOLARO™ service.This Privacy Policy is applicable only to personal information collected through the SOLARO™ service as we maintain and follow separate privacy policies in relation to our non-SOLARO™ business. Please visit www.castlerockresearch.com for our policies regarding our other lines of business.

We take privacy very seriously and are particularly committed to protecting the privacy of minors.  For that reason, we will refuse to open an account for a person under the age of 18 without parental or guardian consent and we reserve the right to verify the existence of that consent.  If you are under 18, please do not attempt to register for membership on SOLARO.com or send any information about yourself to us without consent. If we learn that information from a person under the age of 18 has been submitted to us without proper consent, we will delete that account and information as soon as possible.

We will also fully cooperate with any request to release information to any law enforcement agency when a proper request is received.  We may also take steps to protect the health and well being of members and other parties if we have reason to believe that any of these persons are in danger.

Acceptance and Notification of Changes

WHEN OUR WEBSITE IS ACCESSED OR A STUDENT, WITH PARENTAL CONSENT, OPENS A SOLARO™ ACCOUNT, THE STUDENT AND THE PARENT/GUARDIAN, FOR HIM/HERSELF AND ON BEHALF OF THE STUDENT, AGREES TO THIS PRIVACY POLICY, AS AMENDED. IF A VISITOR, MEMBER OR PROSPECTIVE MEMBER (OR THE PARENT OR GUARDIAN OF ANY OF THOSE PERSONS) DOES NOT AGREE TO THIS PRIVACY POLICY, OR TO ANY CHANGES WE MAY SUBSEQUENTLY MAKE, THE VISITOR, MEMBER OR PROSPECTIVE MEMBER MUST IMMEDIATELY STOP ACCESSING OUR WEBSITE AND THE SOLARO™ SERVICE. If we decide to change our Privacy Policy, we will post any changes on our site and provide notification so that members and their parents will always be aware of what changes have been made to how personal information is collected, used and disclosed, and continued use of the SOLARO™ service shall constitute consent to the changes to the Privacy Policy.

What is “personal information”?

“Personal information” (or similar terms, such as “personally identifiable information) is information about an identifiable individual. It includes such things as name, age, gender, educational background and performance, occupation, contact information, financial information and other information which can be linked to an individual’s identity. It does not apply to the information of non-individuals, such as corporations and other business entities and, generally speaking, to business contact information of individuals.

Collection, Use and Disclosure by SOLARO™

Contact, Billing and Other Information Provided by Members, Parents/Guardians and Visitors

When a student or parent/guardian registers a student as a member with SOLARO.com and the member uses the SOLARO™ service, the member can create his or her own avatar and profile.Members may also submit/post information, such as personal information, comments, messages, etc. to their profiles and to chat rooms, forums and news-boards. A member’s profile, and any information posted on it, is accessible to any friends that a member accepts. Any information that a member posts to chat rooms, forums and news-boards is accessible to all registered members and information posted to forums may be accessible to non-member visitors who are touring the SOLARO™ website. We encourage members to view their Profiles as others would view it by clicking on the Profile link in the top menu. All posting and sharing is done at members’ own risk.

When signing up for the SOLARO™ service, SOLARO™ collects information submitted by and regarding the student, including but not limited to: name, email address, physical address, username (that the user creates), sex (gender), location, age, grade and school attended.  In addition, as parental consent is required to receive the SOLARO™ service, we collect information regarding the parent(s) or guardian(s), including name, email address, physical address and credit card billing information.

A member may change or remove any of his or her personal information visible to other members on their Profile at any time by logging into their account and clicking on the “Profile” and “Preferences” tabs in the top menu, except for username, which is visible to all members.

Members can communicate on SOLARO.com with each other through the SOLARO™ service, without revealing their email addresses or, if they choose, their actual name. As noted above, when a member accepts another member as a friend, the member’s profile, and any information posted on it,is accessible to the accepted friend.

In addition, SOLARO™ allows searches by usernames of members. The default will be that usernames are searchable, however, a member may disable this option through his or her Preferences.

We may use members’ and their parents’/guardians’ external email addresses and other contact information to confirm and administer membership accounts and information, respond to members’ and their parents’/guardians’ inquiries or send updates or other news regarding the SOLARO™ service, but especially to provide parents/guardians with updates regarding their children’s progress. We also use personal information of members included in a member’s Profile and that of members’ parents/guardians to deliver updates and information regarding new features of the SOLARO™ service.

We will disclose information about payment and members and parents/guardians to our third party credit card process provider for billing and payment purposes and where there is suspicious credit card use or a dispute concerning a charge. We may also contact financial institutions directly to verify credit card information provided. In doing so, we may share the information we received about the credit card and the member and cardholder to whom the payment relates.

       

We sometimes receive calls or emails from and/or attempt to contact parents or guardians and credit card holders where a credit card belonging to a person other than the parent or guardian of the member (i.e. the student) has been submitted. We will first attempt to verify the identity of the person inquiring or being contacted as being the credit card holder and, if this is verified, we may release the name of the member (student) for whose membership the credit card information was submitted. It is important that each student has the full consent of the credit card holder before submitting the card number to us to pay for services. We reserve the right to cancel or suspend or restrict an account at any time and prohibit future use of the Solaro.com site if a student attempts to use a credit card without prior authorization.

From time to time, SOLARO™ may hold a promotion, sweepstake or contest on SOLARO.com or otherwise. Members and other participants may be asked to provide personal information such as name, email address or home address or to answer questions in order to participate. If a minor wishes to participate, he or she must have parental consent. In such case, SOLARO.com may collect and use personal information to administer the promotion, sweepstake or contest. What information is being collected and how it may be used or disclosed (and to whom) will be made evident at the time of collection through the relevant promotion, sweepstake or contest rules.

        Educational Information Collected Through Use of the SOLARO™ Service

In addition to contact, billing and profile information and personal information that a member posts, which is described above, SOLARO™ also collects and creates information regarding members’ educational background and activities and performance through members’ use of the online tutoring and testing services provided by SOLARO™.

This educational information is utilized by SOLARO™ only for the purposes of providing the SOLARO™ service to the member in question and only disclosed to the member and parents and/or guardians of the member.

This educational information is also used in a non-personally identifying way to conduct research and analysis regarding the results and performance of the SOLARO™ service in order to improve and customize the SOLARO™ service and develop new products and services. This information may also be utilized and disclosed in aggregated, non-personally identifying form for statistical and research purposes.

        Information Collected Automatically through the SOLARO™ Website

We automatically collect certain information from members and visitors when they access our website. This information can include, among other things:

• the Internet domain and internet protocol (IP) address from which a member or visitor accesses our website,
• the type of browser used (e.g., Internet Explorer, Firefox, Safari, etc.),
• the third party website, if any, from which the visit originated,
• the operating system that the member or visitor is using (e.g., Vista, Windows XP, Macintosh OS, etc.),
• the domain name of the member or visitor’s Internet service provider,
• the search terms that a member or visitor uses on our website,
• the specific web pages and/or content visited, and
• the date, time and duration of visits.

An IP address is a number that is automatically assigned to your computer whenever you are surfing the internet. Web servers (computers that “serve up” web pages) automatically identify your computer by its IP address. When members or visitors request pages from our website, our servers typically log their IP addresses. Your IP address may personally identify you depending, in part, on the naming standards followed by your internet service provider. However, we do not use or disclose this information other than for system administration, statistical purposes, to report non-personal aggregate information to others, and to track the use of our website. Still, you may wish to ask your internet service provider about their policies and practices regarding naming standards.

       

Even where IP addresses are not considered personally identifying, it is not our practice to link IP addresses to anything personally identifiable; that is, the visitor’s session will be logged, but the visitor remains anonymous to us.

However, we reserve the right to use IP addresses to identify a visitor when we feel it is necessary to enforce compliance with our Website Terms of Use or other rules or to: (a) fulfill a government request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our Website, or other users; or (d) in an emergency to protect the health and safety of our Website’s users or the general public.

       

Cookies

A “cookie” is a small piece of information/text sent by a web server to be stored on a user’s web browser so it can later be read back from that browser on subsequent visits to a website. SOLARO.com uses cookies to store users’ preferences and to record session information, and allows communications, advertising, and Web page content to be customized according to browser type and member Profile information. A member or visitor may be able to configure their browser to accept or reject all or some cookies, or to provide notification when a cookie is set, however, cookies must be enabled in order to access most functions on the SOLARO™ website. Since each browser is different, members and visitors should check the "Help" menu of their browsers to learn how to change cookie preferences.

Monitoring

While we do not generally, or undertake any obligation to do so, we may monitor content, messages and other exchanges if we suspect members of being under the age of 18 and utilizing the SOLARO™ service without parental or guardian’s consent or using our services in violation of our Terms of Use or Privacy Policy. Postings that appear on the public areas of the website may be edited, deleted or removed in accordance with our Terms of Use.

Links

SOLARO.com may contain links to other sites.SOLARO™ is not responsible for the privacy policies and/or practices on other sites. Members and visitors should read the privacy policy stated on any site being accessed in order to help protect their privacy. The SOLARO™ Privacy Policy only governs the privacy policies and practices of SOLARO™. Nonetheless, we seek to protect the integrity of our website and business and welcome any feedback about these other sites.

Communications with Non-Members

Using our invitation system, SOLARO™ members can send emails to invite friends to join the service. SOLARO™ stores the email addresses that members provide so that the recipients may be added to the friends list of the member sending the invitations, and also to send reminders of the invitations. SOLARO™ does not sell these email addresses or use them to send any communication except for invitations and invitation reminders. Recipients of invitations from SOLARO.com may request the removal of their information from our database by contacting Solaro.com. Non-members may stop SOLARO.com email invitations and other messages from being sent to any email address you control by clicking the unsubscribe link in the invitation email.

Members must ensure that they have the consent of their invitees that SOLARO™ may collect and use the invitees’ email addresses for the purposes of contacting them for potential membership. If an invitee wishes to subscribe for the SOLARO™ service, the invitee (and/or the invitee’s parent or guardian) will be required to consent to this privacy policy as described herein. If an invitee declines the request or does not respond to a reminder, the invitee’s email address will be removed from SOLARO™’s records within a reasonable time.

Membership De-Activation

Members who wish to deactivate their SOLARO™ account may do so by contacting SOLARO™ in accordance with the Terms of Use. Members’ accounts may also be de-activated by SOLARO™ in accordance with the Terms of Use, including where payments for membership are not made. Personal information relating to members who have deactivated accounts may persist in backup copies of SOLARO™’s databases for a reasonable period of time but will not be available to other members of SOLARO™ and will be subsequently deleted except for information incorporated into aggregated (non-personally identifying) information.

Security

SOLARO™ uses physical and electronic precautions to protect member information stored within our databases, and we restrict access to personal information to those employees and contractors who need to access it to perform their job functions, such as our customer service personnel and technical staff.

SOLARO™ uses member-created usernames and passwords to assist in the security of member accounts. It is a member’s and their parent or guardian’s responsibility to protect their password as disclosure of it allows anyone to access a member’s account, including all of your sent and received messages, profile information and educational information. Members and parent/guardians should also take precautions to protect their email account as anyone can request that a member password be sent to the member’s and/or the parent’s/guardian’s email addresses.  As such, if someone else uses or controls a member’s or parent’s/guardian’s email account, that person may be able to gain access to a member’s SOLARO™ account. To protect a SOLARO™ account, members and parent/guardians should ensure that they do not use the “Remember Me” feature or set their browser to remember details on any public or shared computers.

While we take measures to attempt to protect members and visitor’s information and privacy, we cannot guarantee the absolute security of personal information due to actions of other members with whom members share their pages and information and factors such as unauthorized third party entry or use, or hardware or software failure which may compromise security. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and you do so at your own risk.

For any additional information about the security measures we use on SOLARO.com, please contact us at privacy@Solaro.com

Additional Disclosure of Personal Information

Except as otherwise described in this Privacy Policy, SOLARO™ will not disclose personal information to any third party unless we believe that disclosure is necessary for one of the following reasons: (1) as required by law, including to respond to a subpoena, search warrant or other legal process received by SOLARO.com; (2) to enforce the SOLARO.com Terms of Use or to protect our rights; or (3) to protect the safety of the public and members of and visitors to the service. SOLARO™ also reserves the right to disclose personal information to a potential purchaser of all or part of our business.

How to Contact Us

You can email privacy@Solaro.com to request to see all the information we have collected about you.  To protect your privacy and security, we take reasonable steps to verify your identity before granting access to information held by us or making corrections.

If you have any questions about this Privacy Policy, the practices of this website, or your dealings with SOLARO™, please contact our privacy officer at: privacy@Solaro.com or by mail at  Suite 2340, 10180-101 Street, Edmonton, AB T5J 3S4 .

Created September, 2009.

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