In addition to this Privacy Policy, we provide data and privacy information embedded in our products and certain features that ask to use your personal data. This product-specific information is accompanied by our Data & Privacy Icon. You will be given an opportunity to review this product-specific information before using these features. You also can view this information at any time, either in Settings related to those features and/or online at I CAN READ.com/legal/privacy. Please take a moment to familiarize yourself with our privacy practices, accessible via the headings below, and contact us if you have questions.

What Is Personal Data at I CAN READ?

At I CAN READ, we believe strongly in fundamental privacy rights — and that those fundamental rights should not differ depending on where you live in the world. That’s why we treat any data that relates to an identified or identifiable individual or that is linked or linkable to them by I CAN READ as “personal data,” no matter where the individual lives. This means that data that directly identifies you — such as your name — is personal data, and also data that does not directly identify you, but that can reasonably be used to identify you — such as the serial number of your device — is personal data. Aggregated data is considered non-personal data for the purposes of this Privacy Policy. This Privacy Policy covers how I CAN READ or an I CAN READ-affiliated company (collectively, “I CAN READ”) handles personal data whether you interact with us on our websites, through I CAN READ apps or in person.

Your Privacy Rights at I CAN READ

At I CAN READ, we respect your ability to know, access, correct, transfer, restrict the processing of, and delete your personal data. We have provided these rights to our global customer base and if you choose to exercise these privacy rights, you have the right not to be treated in a discriminatory way nor to receive a lesser degree of service from I CAN READ. Where you are requested to consent to the processing of your personal data by I CAN READ, you have the right to withdraw your consent at any time. To help protect the security of your personal data, you must sign in to your account and your identity will be verified.

Personal Data I CAN READ Collects from You

 At I CAN READ, we believe that you can have great products and great privacy. This means that we strive to collect only the personal data that we need. The personal data I CAN READ collects depends on how you interact with I CAN READ. When you create an I CAN READ account, apply for commercial credit, purchase and/or activate a product or device, download a software update, register for a class at an I CAN READ Store, connect to our services, contact us (including by social media), participate in an online survey, or otherwise interact with I CAN READ, we may collect a variety of information, including:

• Account Information. Your I CAN READ ID and related account details, including email address, devices registered, account status, and age.

• Device Information. Data from which your device could be identified, such as device serial number, or about your device, such as browser type

• Contact Information. Data such as name, email address, physical address, phone number, or other contact information

• Payment Information. Data about your billing address and method of payment, such as bank details, credit, debit, or other payment card information

• Transaction Information. Data about purchases of I CAN READ products and services or transactions facilitated by I CAN READ, including purchases on I CAN READ platforms

• Fraud Prevention Information. Data used to help identify and prevent fraud, including a device trust score

• Usage Data. Data about your activity on and use of our offerings, such as app launches within our services, including browsing history; search history; product interaction; crash data, performance and other diagnostic data; and other usage data

• Location Information. Precise location only to support services such as Find My or where you agree for region-specific services, and coarse location

• Health Information. Data relating to the health status of an individual, including data related to one’s physical or mental health or condition. Personal health data also includes data that can be used to make inferences about or detect the health status of an individual. If you participate in a study using an I CAN READ Health Research Study app, the policy governing the privacy of your personal data is described in the I CAN READ Health Study Apps Privacy Policy.

• Other Information You Provide to Us. Details such as the content of your communications with I CAN READ, including interactions with customer support and contacts through social media channels You are not required to provide the personal data that we have requested. However, if you choose not to do so, in many cases we will not be able to provide you with our products or services or respond to requests you may have.

Personal Data I CAN READ Receives from Other Sources

I CAN READ may receive personal data about you from other individuals, from businesses or third parties acting at your direction, from our partners who work with us to provide our products and services and assist us in security and fraud prevention, and from other lawful sources.

• Individuals. I CAN READ may collect data about you from other individuals — for example, if that individual has sent you a product or gift card, invited you to participate in an I CAN READ service or forum, or shared content with you.

• At Your Direction. You may direct other individuals or third parties to share data with I CAN READ. For example, you may direct your mobile carrier to share data about your carrier account with I CAN READ for account activation, or for your loyalty program to share information about your participation so that you can earn rewards for I CAN READ purchases.

• I CAN READ Partners. We may also validate the information you provide — for example, when creating an I CAN READ account, with a third party for security, and for fraud-prevention purposes. For research and development purposes, we may use datasets such as those that contain images, voices, or other data that could be associated with an identifiable person. When acquiring such datasets, we do so in accordance with applicable law, including law in the jurisdiction in which the dataset is hosted. When using such datasets for research and development, we do not attempt to reidentify individuals who may appear therein.

I CAN READ’s Use of Personal Data

I CAN READ uses personal data to power our services, to process your transactions, to communicate with you, for security and fraud prevention, and to comply with law. We may also use personal data for other purposes with your consent.

I CAN READ uses your personal data only when we have a valid legal basis to do so. Depending on the circumstance, I CAN READ may rely on your consent or the fact that the processing is necessary to fulfill a contract with you, protect your vital interests or those of other persons, or to comply with law. We may also process your personal data where we believe it is in our or others’ legitimate interests, taking into consideration your interests, rights, and expectations. More information is available in the product-specific information embedded in our products and features as described above.

• Power Our Services. I CAN READ collects personal data necessary to power our services, which may include personal data collected to improve our offerings, for internal purposes such as auditing or data analysis, or for troubleshooting.

• Process Your Transactions. To process transactions, I CAN READ must collect data such as your name, purchase, and payment information.

• Communicate with You. To respond to communications, reach out to you about your transactions or account, market our products and services, provide other relevant information, or request information or feedback. From time to time, we may use your personal data to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is important to your interaction with I CAN READ, you may not opt out of receiving these important notices.

• Security and Fraud Prevention. To protect individuals, employees, and I CAN READ and for loss prevention and to prevent fraud, including to protect individuals, employees, and I CAN READ for the benefit of all our users, and prescreening or scanning uploaded content for potentially illegal content, including child sexual exploitation material.

• Personal Data Used for Personalisation. If you choose to personalise your services or communications where such options are available, I CAN READ will use information that we collect so that we can offer you those personalised services or communications.

• Comply with Law. To comply with applicable law — for example, to satisfy tax or reporting obligations, or to comply with a lawful governmental request. I CAN READ does not use algorithms or profiling to make any decision that would significantly affect you without the opportunity for human review. I CAN READ also does not use or disclose sensitive personal data for any purposes that would require a user to exercise a right to limit processing according to California law. I CAN READ retains personal data only for so long as necessary to fulfill the purposes for which it was collected, including as described in this Privacy Policy or in our service-specific privacy notices, or as required by law. We will retain your personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy and our service-specific privacy notices. When assessing retention periods, we first carefully examine whether it is necessary to retain the personal data collected and, if retention is required, work to retain the personal data for the shortest possible period permissible under law.

I CAN READ’s Sharing of Personal Data

I CAN READ may share personal data with I CAN READ-affiliated companies, service providers who act on our behalf, our partners, developers, and publishers, or others at your direction. Further, I CAN READ does not share personal data with third parties for their own marketing purposes.

• Service Providers. I CAN READ may engage third parties to act as our service providers and perform certain tasks on our behalf, such as processing or storing data, including personal data, in connection with your use of our services and delivering products to customers. I CAN READ service providers are obligated to handle personal data consistent with this Privacy Policy and according to our instructions. They cannot use the  personal data we share for their own purposes and must delete or return the personal data once they’ve fulfilled our request.

• Partners. At times, I CAN READ may partner with third parties to provide services or other offerings. I CAN READ requires its partners to protect your personal data.

• Developers and Publishers from Whom You Get a Subscription. If you purchase a third-party subscription from the App Store or within I CAN READ Apps, we create an Account that is unique to you and the developer or publisher. The Account may be used to provide reports to the developer or publisher, which include information about the subscription you purchased and your country of residence. If you cancel all of your subscriptions from a particular developer or publisher, the Account will reset after 180 days if you do not resubscribe. This information is provided to developers or publishers so that they can understand the performance of their subscriptions.

• Others. I CAN READ may share personal data with others at your direction or with your consent, such as when we share information with your carrier to activate your account. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations or users, or in the event of a reorganisation, merger, or sale. I CAN READ does not sell your personal data including as “sale” is defined in Australia. I CAN READ also does not “share” your personal data as that term is defined in Australia.

Protection of Personal Data at I CAN READ

At I CAN READ, we believe that great privacy rests on great security. We use administrative, technical, and physical safeguards to protect your personal data, taking into account the nature of the personal data and the processing, and the threats posed. We are constantly working to improve on these safeguards to help keep your personal data secure. For more information, visit our I CAN READ Platform Security guide.

Children and Personal Data

I CAN READ understands the importance of safeguarding the personal data of children, which we consider to be an individual under the age of 13 or the equivalent age as specified by law in your jurisdiction. That is why I CAN READ has implemented additional processes and protections to help keep children’s personal data safe. To access certain I CAN READ services, a child must have a child I CAN READ Account. A child I CAN READ Account may be created by the parent or, in the case of a Managed I CAN READ Account, by the child’s educational institution.

• Parents. Parents are to create a child account for use of the I CAN Read Apps. I CAN READ will not handle children’s personal data. If a parent agrees to use the I CAN READ services, they must provide I CAN READ with a verifiable parental consent.

• Educational Institutions. Educational institutions that participate in the I CAN READ Program may also create I CAN READ Accounts for students with the parents consent. If we learn that a child’s personal data was collected without appropriate authorisation, it will be deleted as soon as possible.

Cookies and Other Technologies

I CAN READ’s websites, online services, interactive applications, and advertisements may use “cookies” and other technologies such as web beacons. These technologies help us to better understand user behaviour including for security and fraud prevention purposes, tell us which parts of our websites people have visited, and facilitate and measure the effectiveness of advertisements and web searches.

• Communications Cookies. These cookies are used to enable network traffic to and from I CAN READ’s systems, including by helping us detect any errors.

• Strictly Necessary Cookies. These cookies are set as required to provide a specific feature or service that you have accessed or requested. For example, they allow us to display our websites in the proper format and language and to authenticate and verify your transactions.

Our Companywide Commitment to Your Privacy

To make sure your personal data is secure, we communicate our privacy and security guidelines to I CAN READ employees and strictly enforce privacy safeguards within the company.

Privacy Questions

If you have questions about I CAN READ’s Privacy Policy or privacy practices including where a third-party service provider is acting on our behalf, or you would like to contact our head office, please call 02 9411 4144.

You can also ask us questions about how to submit a privacy complaint and we will endeavor to help. I CAN READ takes your privacy questions seriously. A dedicated team reviews your inquiry to determine how best to respond to your question or concern, including those inquiries received in response to an access or download request. In most cases, all substantive contacts receive a response within seven days. In other cases, we may require additional information or let you know that we need more time to respond. Where your complaint indicates an improvement could be made in our handling of privacy issues, we will take steps to make such an update at the next reasonable opportunity. In the event that a privacy issue has resulted in a negative impact on you or another person, we will take steps to address that with you or that other person. You may at any time — including if you are not satisfied with I CAN READ’s response — refer your complaint to the applicable regulator. If you ask us, we will endeavour to provide you with information about relevant complaint avenues which may be applicable to your circumstances. When there is a material change to this Privacy Policy, we’ll post a notice on this website at least a week in advance of doing so and contact you directly about the change if we have your data on file.