Ochrana osobných údajov
Last updated on February 22, 2017.
Our Commitment to Privacy
Pixton Comics Inc. is committed to maintaining the security, confidentiality and privacy of your personal information (which includes the personal information of your students).
Scope of Policy
This Policy applies to our collection, use and disclosure of your personal information in connection with our website and services. This Policy does not impose any limits on our collection, use or disclosure of the following (non-student related) information:
- business contact information; and
- certain publicly available information.
We have designated a Privacy Officer who is responsible for our compliance with this Policy. The Privacy Officer may be contacted as described below.
What Do We Collect?
We collect the following types of personal information from all Pixton members:
- IP address; and
- Browser and operating system descriptor.
Additionally, we may collect the following types of personal information:
- screen name and password;
- email address (required for Educators, optional for Students);
- name (optional for Students; does not have to be real name); and
- institution name, address, city, province/state, country, postal/zip code, phone number, first name, last name, title (main Educator or Administrator only).
How Do We Collect Information?
We collect information in a variety of ways, including the following:
- sign-up forms;
- profile fields (freestyle text fields);
- the Google Interactive map (Educators only; if you indicate your approximate location on it);
- send-to-a-friend forms;
- our "Contact Us" form; and
- email messages which may contain code that allows us to track whether the message was opened and/or links clicked.
We strongly advise you not to submit personal information as part of comments, comics, private messages, or other content you create. However, if you do, the information will be stored in our database and treated the same as other personal information collected from you.
We collect, use and disclose your personal information for the following purposes:
- to respond to or follow-up regarding any comments you submit to us;
- to open your membership account;
- to authenticate your identity;
- to track email and site usage statistics;
- to protect us, you and others from fraud and error and to safeguard our business interests;
- to comply with legal and regulatory requirements;
- as part of a sale of any or all of our business;
- to apply our policies, such as minimum age policies;
- to process your payments through our third party payment processors (applicable to main Educator or Administrator only);
- to facilitate communication and sharing among our members;
- to allow members to share comics with their friends and tell their friends about our site; and
- to integrate third-party authentication, namely Google, Edmodo, Office365, and RMUnify single sign-on.
The above collections, uses and disclosures are a reasonably necessary part of your relationship with us. We might also collect, use and disclose your personal information for the following purposes:
- to personalize your experience with us through our website and through our customer service representatives;
- to communicate to members news about us and our services;
- to evaluate and improve our products and services;
- to invite you to participate in Pixton surveys, contests or special events (Educators only); and
You may instruct us to refrain from using or sharing your personal information in any or all of the four ways described above at any time by providing written notification to our Privacy Officer. We acknowledge that the sharing of your personal information in any or all of the four ways described above is at your option and we will not refuse you access to any product or service merely because you have advised us to stop using or sharing your personal information in any or all of the four ways shown. You may also opt out of certain disclosures by logging into your Pixton account, navigating to your Account Settings page, and changing your email notification and privacy settings (if applicable to your account).
If we want to use your personal information for a new purpose, we will disclose this to you and ask for your consent unless the new use is already authorized or required by law.
Specific 3rd Party Services
Our website makes use of the following 3rd party services:
- Google Analytics collects non-personally identifiable information, which we use in aggregate to track the usage of our website. No comic data is passed to the service.
- Intercom.io (Educators only) is a customer communication tool that allows us to send email and in-application support messages to users. We use it to segment users for more specific messaging; to organize messages; to help with ticketing; and to communicate product updates such as feature releases. This service collects limited personally identifiable information, such as name, email address, and location.
- Stripe.com (Educators only) is a payment processor, which we use to collect credit card payments from customers.
- Xsolla.com (Educators only) is a payment processor, which we use to collect payments from customers via various methods, which vary according to user's country.
If a Student chooses their own password, an Educator should first discuss best practices with the Student, namely:
- Make the password difficult to guess;
- Never share the password with another person, other than the Educator.
If a Student forgets their password, the password can be reset using one of the following methods:
- If there is an email address associated with the Student's account, the Student must submit their email address at Pixton.com/reset-password and then follow the instructions received by email.
- If there is not an email address associated with the Student's account, the Educator has the ability to set a new one for the Student, by navigating in the main menu to My People > Students.
If an Educator sets a Student's password, it may be stored in an encrypted form along with a decryption hash, which is used to display that password back to the Educator upon authorized request. Otherwise, all passwords in our database are one-way encrypted and it is not otherwise possible to know a password.
If a Pixton account is linked to a 3rd party service via Single Sign-on (SSO), then no Pixton specific password exists.
Educators can see all comics created by Students within their Group(s), whether published or in progress. In case there is any concern about the content of a Student's comic, the Educator has the ability to delete, modify, or send the comic back to the Student for revision.
Educators may choose to turn on Teacher Moderation, whereby all comics submitted by a Student must be approved by the Educator before having the potential to be shared, both externally and within Pixton pre školy. Once a comic is approved, it may be shared online by direct link or embed code, in which case the Student's name and/or screen name appears as 'Anonymous'.
Educators can turn off external sharing completely, on a per-Group basis, as follows:
- In the main menu, go to My People > Groups
- Click Edit
- Under Moderation & Permissions, uncheck "share comics outside Pixton via embed code or direct link"
- Click Save Group
We will obtain your consent to collect, use or disclose personal information except where we are authorized or required by law to do so without consent. For example, we may collect, use or disclose personal information without your knowledge or consent where:
- the information is publicly available, as defined by statute or regulation;
- we are obtaining legal advice; or
- we reasonably expect that obtaining consent would compromise an investigation or proceeding.
Other exceptions may apply.
Your consent can be express, implied or given through an authorized representative such as a lawyer, agent or parent.
Consent may be provided orally, in writing, electronically, through inaction (such as when you fail to notify us that you do not wish your personal information collected/used/disclosed for various purposes after you have received notice of those purposes) or otherwise.
You may withdraw consent at any time, subject to legal, contractual and other restrictions, provided that you give reasonable notice of withdrawal of consent to us. On receipt of notice of withdrawal of consent, we will inform you of the likely consequences of the withdrawal of consent, which may include the inability of us to provide certain services for which that information is necessary.
Limits on Collection of Personal Information
We will not collect personal information indiscriminately but will limit collection of personal information to that which is reasonable and necessary. We will also collect personal information as authorized by law.
Limits for Using, Disclosing and Retaining Personal Information
Your personal information will only be used or disclosed for the purposes set out above and as authorized by law.
We will keep personal information used to make a decision affecting you for at least one year after using it to make the decision, except to the extent that you delete or remove that information yourself. If you choose to end your membership with us, it is your responsibility to delete your information if you do not want us to retain it for this one-year period.
We will destroy, erase or make anonymous documents or other records containing personal information as soon as it is reasonable to assume that the original purpose is no longer being served by retention of the information and retention is no longer necessary for a legal or business purpose. Please note, however, it is sometimes not possible or practical to delete information from all backup media, especially if that media is stored offsite or contains co-mingled data.
We will take due care when destroying personal information to prevent unauthorized access to the information.
We will make a reasonable effort to ensure that personal information we are using or disclosing is accurate and complete.
If you demonstrate the inaccuracy or incompleteness of personal information, we will amend the information as required. If appropriate, we will send the amended information to third parties to whom the information has been disclosed.
When a challenge regarding the accuracy of personal information is not resolved to your satisfaction, we will annotate the personal information under our control with a note that the correction was requested but not made.
Safeguarding Personal Information
We protect the personal information in our custody or control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks.
We will take reasonable steps, through contractual or other reasonable means, to ensure that a comparable level of personal information protection is implemented by the suppliers and agents who assist in providing services to us. Some specific safeguards may include:
- physical measures such as locked filing cabinets, or not leaving computers unattended when logged in;
- organizational measures such as restricting employee access to files and databases as appropriate;
- electronic measures such as passwords and firewalls; and
- investigative measures where we have reasonable grounds to believe that personal information is being inappropriately collected, used or disclosed.
However, absolute privacy cannot be guaranteed for any comic, private message or other content posted on or shared through Pixton, so we strongly recommend that you do not include sensitive personal information in any online content on or through Pixton.
You have a right to access your personal information held by us.
Upon written request and authentication of identity, we will provide you your personal information under our control. We will also give you information about the ways in which that information is being used and a description of the individuals and organizations to whom that information has been disclosed. We may charge you a reasonable fee for doing so.
We will make the information available within 30 days of receiving a written request or provide written notice where additional time is required to fulfil the request.
In some situations, we may not be able to provide access to certain personal information (e.g., if disclosure would reveal personal information about another individual, the personal information is protected by solicitor/client privilege, the information was collected for the purposes of an investigation or where disclosure of the information would reveal confidential commercial information that could harm the competitive position of us). We may also be prevented by law from providing access to certain personal information.
Where an access request is refused, we will notify you in writing, document the reasons for refusal and outline further steps which are available to you.
We will, on request, provide information regarding our complaint procedure.
Any inquiries, complaints or questions regarding this Policy should be directed in writing to our Privacy Officer as follows:
Pixton Comics Inc.
P.O. Box 238
Parksville, BC, Canada V9P 2G4
1 (888) 774-9866
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