Privacy Policy

Last updated 1 February 2025

This Privacy Policy for Glassfish Education, LLC (“we,” “us,” or “our”), describes what data we collect, as well as how and why we might access, collect, store, use, and/or share or process your personal information when you use our Services, including:

DecipherInk mobile application
www.decipherink.net

This Privacy Policy is to help you understand our processes and your rights and choices. If you do not agree with our policies and practices, please do not use our Services.

What information do we collect?

Personal Information You Disclose to Us

We collect personal information that you voluntarily provide to us when you register on the Services, when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise contact us.

Personal Information Provided By You

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect from you may include:

Name(s)
Email address(es)
Password(s)

You are responsible for the accuracy and completeness of the information you provide to us and are likewise responsible for keeping that information up to date. Any issues arising from inaccurate or incomplete information are your responsibility.

Sensitive Information

We do not request or process sensitive information.*

* What is the definition of "sensitive information"? Sensitive information refers to data that, if exposed or mishandled, could lead to serious consequences, including privacy violations, identity theft, financial loss, or other forms of harm. This type of information is often protected by law and requires strict handling procedures to ensure confidentiality and security.

Categories of Sensitive Information:

Personally Identifiable Information (PII) such as Social Security numbers, addresses, birthdates, and passport numbers.
Protected Health Information (PHI) such as medical records, health insurance information, and any data related to an individual's health status or care.
Financial Information such as bank account details, credit card numbers, and financial transaction records.
Intellectual Property such as trade secrets, proprietary business information, and patent details.
Legal Information such as confidential legal documents, contract details, and privileged communication.
Operational Information such as internal business processes, strategies, and employee records.

Payment Data

We may collect data necessary to process your payment if you choose to make purchases. All payment data is handled and stored by Stripe and is subject to their Privacy Policy. You may find Stripe's Privacy Policy here: Stripe Privacy Policy

Application Data

If you use our application, we may also do the following if you choose to provide us with permission.

Push Notifications: We may request permission to send you push notifications regarding your account or certain features of the application. If you wish to opt out from receiving these types of communications, you may turn them off in your device’s settings.

Information Automatically Collected

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identify (such as your name or contact information) but may include device and usage information, such as IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed and used to deliver our Services appropriately (e.g. adapt to the size and type of your device), to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take (such as which features you use)), device event information (such as system activity, error reports, and hardware setting).

Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, or system configuration information.

Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise.

Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model, Internet service provider, and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application you accessed.

We do not use Cookies or similar technologies.

How do we process your information?

We process your personal information for a variety of reasons depending on how you interact with our Services, including:

To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
To deliver and facilitate the delivery of services to the user. We may process your information to provide you with the requested service.
To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
To send administrative information to you. We may process your information to send you details and our products and services, changes to our terms and policies, and other similar information.
To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
To send marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your specified marketing preferences. You can opt out of receiving marketing communications at any time.
To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.
To identify usage trends. We may process information about how to use our Services to better understand how they are being used so we can improve them.
To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.

What legal bases do we rely on to process your information?

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information.

Consent. We may process your personal information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time by not accessing the Services or by deleting your account.
Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services at your request prior to entering into a contract with you.
Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
- 1. 1. 1. Send users information about special offers and discounts on our products and services.
        Analyze how our Services are used so we can improve them to engage and retain users.
        Support our marketing activities.
        Diagnose problems and/or prevent fraudulent activities.
        Understand how our users use our products and services so we can improve user experience.
Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

In legal terms, we are generally the “data controller” under European data protection laws of the personal information described in this Privacy Policy, since we determine the means and/or purposes of the data processing we perform.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time by not using our Services or by deleting your account.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including for example:

If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
For investigations and fraud detection and prevention
For business transactions provided certain conditions are met
If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
For identifying injured, ill, or deceased persons and communicating with next of kin
If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
If the collection is solely for journalistic, artistic, or literary purposes
If the information is publicly available and is specified by the regulations

When and with whom do we share your personal information?

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information to do that work.

The categories of third parties we may share personal information with are as follows:

Cloud Computing Services

Data Analytics Services

Data Storage Service Providers

Finance & Accounting Tools

Order Fulfillment Service Providers

Payment Processors

Performance Monitoring Tools

Sales & Marketing Tools

User Account Registration & Authentication Services

Website Hosting Service Providers

We also may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

We do not collect information to sell to third parties or advertisers. Your data is used solely for the purposes described in this Privacy Policy, ensuring a secure and private experience while using our services.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered “selling” or your personal information.

We have not disclosed, sold, or shared any personal information to third parties for business or commercial purposes in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, or other consumers.

We do not use Cookies or similar technologies.

What is our stance on third-party websites?

The Services may link to third-party websites, online services, resources, or mobile applications that are not affiliated with us, and may link to additional websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link toward a third-party website, service, or application does not imply endorsement by us. We cannot guarantee the safety and privacy of data you provide to third parties. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content or privacy or security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.

If our Services have a link to a third-party that is found to be fraudulent, damaging, or harmful in another way, we would like to be informed so as to remove the link or association. Please contact us at hello@decipherink.net in any such instances.

Is your information transferred internationally?

Our servers are located in the United States and data is not transferred internationally. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information in the United States.

How long do we keep your information?

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than a period of twelve (12) months past the termination (deletion) of the user's account, or thirty-six (36) months past the start of the idle period of the user’s account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

How do we keep your information safe?

We have implemented appropriate and reasonable technical and organization security measures designed to protect the security of the personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk.

Do we collect information from minors?

We do not knowingly collect, solicit data from, or market to children under 13 years of age. We do not sell any personal information, including that of minors. By using the Services, you represent that you are at least 13 years of age or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services.

We collect only login information and usage data for internal purposes, as specified above. There is no user submitted content and no user-to-user interaction.

What are your privacy rights?

Opting Out. You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails we send, or by contacting us at hello@decipherink.net. You will then be removed from the marketing lists. However, we may still communicate with you - for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Review or change account information. If at any time you would like to review or change the information in your account you can:

Log into your account settings and update your user account information.

Delete your account. By using our Services you consent to the Terms and Conditions and our Privacy Policy. You may withdraw your consent by deleting your account. If you would like to delete your account you can:

Log into your account settings and delete your account.

Upon your request to terminate your account we will deactivate or delete your account and information from our active database. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms, and comply with applicable legal requirements.

Additional legal rights.

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law and reasonable justification. These rights include:

Right to know whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request the deletion of your personal data
Right to obtain a copy of your personal data
Right to non-discrimination for exercising your rights
Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or the profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)

Depending on the state where you live, you may also have the following rights:

Right to access the categories of personal data being processed (as permitted by applicable law, including Minnesota’s privacy law)
Right to obtain a list of categories of the parties to which we have disclosed personal data (as permitted by applicable law, including California’s and Delaware’s privacy laws)
Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including Minnesota’s and Oregon’s privacy laws)
Right to review, understand, question, and correct how personal data has been profiled (as permitted by by applicable law, including Minnesota’s privacy law)
Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California’s privacy law)
Right to opt out of the collection of sensitive data and personal data collected through the operation of voice or facial recognition feature (as permitted by applicable law, including Florida’s privacy law)

How to Exercise Your Rights

To exercise these rights you can contact us by sending an email to hello@decipherink.net or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have valid authorization to act on your behalf in accordance with applicable laws.

Request verification. Upon receiving a request we will need to verify your identity to determine that you are the same person about whom we have information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

Appeals. Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at hello@decipherink.net. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California “Shine The Light” Law

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by sending an email to hello@decipherink.net.

Do United States residents have specific privacy rights?

If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Specific rights for other regions?

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia’s Privacy Act 1988 and New Zealand’s Privacy Act 2020 (Privacy Act).

This privacy notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.

If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it may affect our ability to provide our services, in particular:

offer you the products or services that you want
manage your account with us
respond to or help with your requests
confirm your identity and protect your account

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section “Contact.”

If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and for a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.

Republic of South Africa

If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator, the details of which are:

The Information Regulator (South Africa)

General enquiries: enquiries@inforegulator.org.za

Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za & POPIAComplaints@inforegulator.org.za

Updates to this Notice

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “Revised” date at the top of the Privacy Policy. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting and using your information.

Contact

If you have questions or comment about this Privacy Policy, you may contact us by email at hello@decipherink.net or by post at:

Glassfish Education, LLC

125 W. Oak Drive

Woodland Hills, UT 84653

United States

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