Squarebit LLC 

Privacy Notice

Last updated January 2, 2024

This Privacy Notice for Squarebit LLC and our affiliates and subsidiaries (collectively, “Squarebit,” “us,” or “we”) is governed by and part of our Terms of Use. We at Squarebit know you care about how your information is used and shared, and we take your privacy seriously. Please read this Privacy Notice carefully to understand our privacy practices. Any capitalized terms not defined in this Privacy Notice have the meanings provided in the Terms of Service. Any additional notices we may provide you about our privacy practices will be considered to form part of this Privacy Notice.

Scope

This Privacy Notice describes how we treat information collected through https://www.squarebitstudios.com and other websites, platforms and channels we own or operate (collectively, the “Site”). Your use of the Site is subject to this Privacy Notice and our Terms of Use, including its applicable limitations on damages and the provisions regarding resolution of disputes.

Consent

By using or accessing the Site in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Notice, and you hereby consent that we will collect, use, and share your information in the following ways. If you do not agree with this Privacy Notice, do not use our Site.

Personal Information

As used in this Privacy Notice, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, such as:

• Identifiers (e.g., real name, alias, address, username, IP address, email address)

• Protected Information (e.g. race, citizenship, marital status, sex)

• Biometric information (e.g., DNA, face/voice prints, health data) and audio, electronic, visual, thermal, olfactory, or similar information;

• Commercial information (e.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);

• Employment-related information (e.g. current or past employment); 

• Non-public educational information, including information protected under the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99);

• Internet activity (e.g., interactions with a website, content, or advertisement); 

• Inferences drawn from Personal Information to create a profile about preferences, characteristics, trends, predispositions, behavior, attitudes, and aptitudes; and

• Sensitive Personal Information (e.g. social security or government ID number; precise geolocation; racial or ethnic origin; biometrics; health information; union membership; contents of messages when we are not the recipient).

Personal Information does not include (i) publicly available information (ii) aggregate information, meaning data about a group or category of services or users from which individual identities and other Personal Information has been removed; or (iii) deidentified information that cannot reasonably be used to infer information about, or otherwise be linked to, a particular consumer. 

Children’s Privacy

Squarebit  is designed for users age 16 and older. We do not knowingly collect Personal Information from children under 16. If we discover that a child under 16 has provided us with Personal Information, we will delete such information from our systems. If you believe we might have any information collected online from a child under 16, or if you become aware of any unauthorized submission of information to us, please contact us at contact@squarebitstudios.com.

Information We Collect

The types of Personal Information we collect about you and the manner of collection depends on how you interact with us, as detailed below. We only collect your Personal Information (i) with your consent, (ii) if we have a legitimate interest in doing so, or (iii) as authorized or required by law. We only collect, use, retain and share Personal Information as reasonably necessary and proportionate to achieve our purposes, or for other purposes that we disclose to you and are compatible with the context of how we collected the Personal Information.

Categories: During the preceding 12 months, we have collected these categories of Personal Information:

• Identifiers   

• Employment-related information 

• Internet or other similar activity 

Sources: We collect Personal Information from these sources:

• Directly from you when you communicate with us, with your consent. If you contact us by email, online form, our social media or other channels, or other means to request information or support, we will collect your name, email address, company name, and any other information you choose to provide in your communication to us. We collect this information with your consent, and we use it for purposes related to your inquiry or as otherwise stated at the time of collection.

• Indirectly from your use of the Site, with a legitimate interest. We automatically collect details about your use of the Site, such as your (i) session active time and related data; (ii) device data (e.g., IP address, operating system, browser type, device ID, mobile network information); and (iii) usage details (e.g., the content, features, or resources you access and use; specific functions completed). Like most websites, we use cookies and other technologies to track how you use the Site. Please read about our use of Cookies for more information. We collect this information to achieve our legitimate interest of providing and improving our Site. We may also use this information to deliver targeted marketing.

Squarebit  will not collect additional categories of Personal Information or use your Personal Information for purposes that are incompatible with the purpose stated at the time of collection without first notifying you, either by updating this Privacy Notice or through other means.

Retention of Personal Information: Squarebit  retains all categories of Personal Information we collect for the period necessary to respond to your inquiries or provide you with any information or services you request from us. We regularly review and delete or deidentify Personal Information that we no longer need to provide you with our services or for our business purposes.

Other Uses: In addition to the specific uses detailed above, we might use also your Personal Information to:

• Provide, maintain and improve our Site.

• Send you support and administrative messages.

• Monitor your compliance with any of your agreements with us. 

• Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Company and others.

• Protect your privacy and enforce this Privacy Notice.

• If we believe it is necessary, to identify, contact or bring legal action against persons or entities who may be causing injury to you, to us, or to others.

• Comply with a law, regulation, legal process or court order.

• Fulfill any other purpose to which you consent.

Disclosing Personal Information

Categories: We will only disclose Personal Information as described in this section, with your permission, or as required by law. In the preceding 12 months, we have disclosed the following categories of Personal Information for a business purpose:

• Identifiers   

• Employment-related information 

• Internet or other similar activity 

Recipients: We may disclose Personal Information to the following recipients:

• Service Providers. Squarebit uses a variety of service providers such as data hosting companies, SMS message delivery services, analytics services, and payment processors. The type of information that we share with a service provider will depend on the service that they provide to us. Our service providers are subject to contractual agreements that protect your Personal Information, and we require all service providers to maintain confidentiality standards that are commercially reasonable to ensure the security of your Personal Information. 

• Government Agencies. We reserve the right to disclose Personal Information to law enforcement and other governmental agencies, at our sole discretion in connection with an investigation of any matter that is illegal or that could expose Squarebit or our subsidiaries to liability.

• Cookie Information Recipients. In some cases, we may allow specific cooperating entities to use cookies or similar technologies to collect non-personal data from your browser or device for measurement purposes. Receipt and use of such information is subject to each cookie information recipient’s Privacy Notice.

• Affiliates and Third Parties. We may disclose the Personal Information we collect about you to our affiliates like a parent company or subsidiaries. For example, we share Personal Information for customer support purposes, marketing, or technical operations. Under specific circumstances, we may disclose Personal Information to certain third parties as permitted by applicable law. For example, if we go through a business transition (e.g., merger, acquisition, or sale of a portion of our assets), as needed to comply with a legal requirement or a court order, when we believe it is appropriate in order to take action regarding illegal activities or prevent fraud or harm to any person; to exercise or defend our legal claims, or for any other reason with your consent.

Aggregated and Deidentified Information: We reserve the right to disclose aggregated, anonymized, or deidentified information about any individuals with our trainer, training managers, speakers, rights holders and other partners, as well as with nonaffiliated entities for marketing, advertising, research or other purposes, without restriction. For example, we may share reports showing trends about the general use of our Site without identifying any particular individual. 

Limited Sensitive Personal Information: Squarebit does not knowingly collect any Sensitive Personal Information, and in no case will Squarebit use or disclose any Sensitive Personal Information for the purpose of inferring characteristics about you. If this ever changes in the future, we will update this Privacy Notice and provide you with methods to limit use and disclosure of Sensitive Personal Information.

No Sale or Sharing With Third Parties: Squarebit does not sell your Personal Information or share your Personal Information with third parties for cross-contextual advertising purposes. If this ever changes in the future, we will update this posting and provide you with methods to opt-out of such sale and sharing.

Your Privacy Rights

Squarebit takes your privacy seriously and honors your rights to control the collection and use of your Personal Information. At any time, you may directly control how we collect and use your Personal Information by taking the following actions:

• Email Communications. We may send you promotional emails about Squarebit or alert you of service changes via our product support system. If you do not wish to receive emails from us, you may change your preferences via the links provided in the emails or by sending a request to contact@squarebitstudios.com to be removed from our email list. Note that if you opt-out of marketing communications, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.

• Texting Consent. If you provide us with your wireless phone number, you consent to Squarebit sending you informational text messages. The number of texts that we send to you will be based on your circumstances and the services you request from us. You can unsubscribe from text messages by replying STOP or UNSUBSCRIBE to any of these text messages. Messaging and data charges may apply to any text message you receive or send. Please contact your wireless carrier if you have questions about messaging or data charges.

• Do Not Track. Do Not Track signals are signals sent through a browser informing us that you do not want to be tracked. Currently, our systems do not recognize browser “do-not-track” requests. If this changes in the future, we will update this Privacy Notice.

In addition to these general privacy rights, you may have additional privacy rights or be entitled to additional controls over your Personal Information depending on where you reside. Please see our supplemental notices specific to residents of California, the European Union, and Canada. 

Consumer Privacy Requests: If you wish to exercise your privacy rights beyond the methods described above, or if you want to express concerns, lodge a complaint, or request information, please submit a verifiable Consumer Privacy Request by sending an email to contact@squarebitstudios.com.

Squarebit can only fulfill a Consumer Privacy Request when we have sufficient information to verify that the requester is the person or an authorized representative of the person about whom we have collected Personal Information, and to properly understand, evaluate, and respond to the request. We do not charge a fee to process or respond to a verifiable request unless we have legal grounds to do so. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

We endeavor to respond to Consumer Privacy Requests in accordance with the requirements of the law applicable to your jurisdiction. Depending on the circumstances and the nature of your request, we may be unable to fulfill your request in part or in whole, for example, if your request falls within a statutory exception or if fulfilling your request would prevent us from complying with a statutory or contractual obligation. 

California Privacy Rights

This section provides residents of the State of California (“California Consumers”) with the disclosures and notices required under the California Consumer Privacy Act of 2018 (“CCPA”). The following paragraphs apply solely to California Consumers and describe the specific rights afforded under the CCPA. California Consumers may exercise the following rights over their Personal Information, subject to any exceptions and limitations that may apply:

• Right to Disclosure. You have the right to request that we disclose information to you about our collection and use of your Personal Information, such as: (i) the categories of Personal Information we have collected about you; (ii) the categories of sources for the Personal Information we have collected about you; (iii) our business or commercial purpose for collecting, selling or sharing your Personal Information; (iv) the categories of third parties with whom we disclose your Personal Information; and (v) a list of specific pieces of Personal Information we have collected about you. You also have the right to request that we disclose the categories of your Personal Information we have sold or shared  and the categories of third parties to whom that Personal information was sold or shared, as well as the categories of Personal information disclosed for a business purpose and the categories of recipients of that information. Squarebit is only required to respond to two disclosure requests from you within a 12-month period. 

• Right to Access. You have the right to request that we provide you with access to specific pieces of Personal Information we have collected about you over the past 12 months (also called a data portability request). If you submit a right to access request, we will provide you with copies of the requested Personal Information in a portable and readily usable format. Please note that Squarebit may be prohibited by law from disclosing copies of certain Personal Information when the disclosure would create a substantial, articulable, and unreasonable risk to the security of the information, our systems, or your account. We are only required by law to respond to two access requests from you within a 12-month period.  

• Right to Correct. If you discover that we maintain inaccurate Personal Information about you, or if your Personal Information changes, please inform us and we will update our records to reflect the correct information.

• Right to Deletion. You have the right to request that we delete Personal Information that we collected from you and retained, with certain exceptions. Squarebit may permanently delete, deidentify, or aggregate the Personal Information in response to a request for deletion. If you submit a right to deletion request, we will confirm the Personal Information to be deleted prior to its deletion, and we will notify you when your request is complete.

• No Selling or Sharing Personal Information. Squarebit does not sell your Personal Information or share your Personal Information with third parties for cross-contextual behavioral advertising purposes. If this changes in the future, we will update this Privacy Notice and provide you with a method to opt-out of such sale and sharing. 

• Limited Use and Disclosure of Sensitive Personal Information. Squarebit does not use or disclose your Sensitive Personal Information for the purpose of inferring characteristics about you. If this ever changes in the future, we will update this Privacy Notice and provide you with methods to limit use and disclosure of Sensitive Personal Information.

• Right to Nondiscrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by law, we will not: (i) deny you goods or services; (ii) charge you different prices or rates for goods or services; (iii) provide you a different level or quality of goods or services; or (iv) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services, because you exercised a right under the CCPA.

• Right to Disclosure of Marketing Information. Under California’s Shine the Light Act (Ca. Civ. Code § 1798.83-1798.84), California Consumers are entitled to request certain disclosures about Personal Information sharing with affiliates and/or third parties for marketing purposes. Please contact us if you wish to obtain these disclosures.

California Consumers may exercise the following rights over their Personal Information, subject to our receipt of a verifiable Consumer Privacy Request, as well as any exceptions and limitations that may apply. Note that if we process your Personal Information in our capacity as a service provider, then we cannot fulfill your request directly. In that case, we will relay your request to the appropriate Customer for further processing and fulfillment. 

European Union Privacy Rights 

We adopted this section to comply with the European Union’s General Data Protection Regulations (“GDPR”). This section applies solely to residents of the European Union (“EU Residents”). If you are an EU Resident, you have the following rights regarding the Personal Information we hold about you:

• Right to know how we process your Personal Information. We have set the required notices in this Privacy Notice. We may provide you with additional notices about other ways we process your Personal Data, such as by sending you a notice via email or by other means of communication.

• Right to access your Personal Information. You may exercise your right to access by logging into your account to view or export your Personal Information. Alternatively, if you submit a Consumer Privacy Request we will provide you with a copy of your Personal Information, along with details about the types of Personal Information we process, why we process it, and any third parties we work with to collect Personal Information on our behalf. We may have one or more legally valid reasons to refuse your request in whole or in part, for example in order to protect the rights of other individuals.

• Right to restrict processing of your Personal Information. You can request that we restrict the processing of your Personal Information if: (i) the data is inaccurate; (ii) the processing is unlawful; (iii) we no longer need the Personal Information; or (iv) you exercise your right to object.

• Right to rectify your Personal Information. If you become aware that the Personal Information that we hold about you is incorrect, or if your situation changes (e.g., you change address), you may edit the Personal Information in your profile or saved to your account, or you can inform us and we will update our records for accuracy.

• Right to data portability. In some circumstances, we are required to provide your Personal Information to another organization at your request and in a structured, commonly used machine-readable format. Please submit a Consumer Privacy Request if you require assistance.

• Right to erasure (a.k.a. the “right to be forgotten”). You may exercise your right to deletion by submitting a Consumer Privacy Request to delete your Personal Information, we will confirm the Personal Information to be deleted prior to its deletion, and we will notify you when your request is complete. This right is not absolute, and we may be entitled to retain and process your Personal Information despite your request. If you make this request, we balance certain legal, contractual, and business interests against your right to request the deletion of your Personal Information.

• Right to object to certain processing of your Personal Information. Upon your request, and in certain circumstances and where we are required to do so by law, we will limit our processing of your Personal Information as you request.

• Right to not be subject to Automated Decision-Making. Squarebitdoes not use Automated Decision-Making (“ADM”). If we engage in this activity in the future, you will have the right to object to a decision we make wholly by a computer or algorithm without human input and to receive information about this type of processing. 

EU Residents may exercise their privacy rights by submitting a verifiable Consumer Privacy Request (sometimes called a data subject access request). Note that if we process your Personal Information in our capacity as a data processor, then we cannot fulfill your request directly. In that case, we will relay your request to the appropriate Customer for further processing and fulfillment. 

Canadian Privacy Rights

We adopted this section to provide supplemental information in compliance with Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”). This section applies solely to residents of Canada where PIPEDA applies (“Canadian Consumers”) and describes PIPEDA rights and explain how Canadian Consumers can exercise those rights. 

• Right to know why we collect, use and distribute the Personal Information we process. We have set the required notices in this Privacy Notice. We may provide you with additional notices about other ways we process your Personal Data, such as by sending you a notice via email or by other means of communication.

• Right to expect us to collect, use, or disclose Personal Information responsibly and not for any other purpose other than which you consented. We set your expectations in this Privacy Notice and collect express or implied consent at various stages of collection or processing. If we collect or use your Personal Information based on your consent, we will also notify you of any changes and will request your further consent as needed. You may withdraw your consent at any time with reasonable notice by contacting us at contact@squarebitstudios.com.

• Right to accuracy of your Personal Information. We take steps to reasonably ensure that your Personal Information we are using is accurate. In most cases, we rely on you to ensure that the Personal Information in your account is current, complete, and accurate.  We provide methods for you to correct, update, and delete inaccurate Personal Information in your account, and we will provide you with reasonable assistance to ensure that your Personal Information is accurate in our systems and with our service providers.

• Right to access your Personal Information. You may access your Personal Information my logging into your account. Alternatively, upon written request and identity authentication, we will provide you with your Personal Information under our control, information about the ways that information is being used, and a description of the entities to whom that information has been disclosed. If limited by law or potential infringement on another’s privacy rights, we may not be able to provide access to some or all of the Personal Information you request. If we must refuse an access request, we will notify you in writing, document the reasons for refusal, and outline further steps available to you.

Canadian Consumers may exercise their privacy rights by submitting a verifiable Consumer Privacy Request. 

Cookies

Cookies are small data files stored on your device that help us track and analyze data to improve our Site and your experience. Cookies serve a variety of purposes, for example analyzing use of a website or platform, navigating between pages efficiently, remembering your preferences, and generally improving your browsing experience. Cookies are generally used for functionality, security, analytics, or advertising. 

Squarebit uses functional cookies and analytics cookies on the Site to collect data about web traffic and visitor interactions and to provide certain features on the Site. All of the cookies used on the Site are set via our website development and hosting third party services providers. You can learn more about the cookies set on the Site by reviewing the latest cookie information on the Google privacy policy

You can adjust your browser or device settings to refuse all or some cookies or to alert you when cookies are being sent. You can also install third-party plugins to control cookie behavior. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the Site may be inaccessible or not function properly. If you get a new device, install a new browser, or erase or otherwise alter your device’s cookie file or privacy settings, your privacy preferences may not be saved. You may see a cookie consent notice on the Site that lists the categories of cookies we use and provides the option to accept or reject different types of cookies. When you consent to cookies on our cookie consent banner, we may set cookies in correspondence with your selections. You may adjust your cookie selections at any time, and we will display the cookie consent notice to you periodically. 

Data Security

Squarebit implements reasonable and appropriate security procedures and practices to help protect your Personal Information from unauthorized or illegal access, destruction, use, modification, or disclosure. We ensure that Squarebit employees, contractors and agents responsible for handling user inquiries are informed of applicable privacy law requirements and we restrict access to those who need that information in order to process it. Please note, however, that no transmission of data over the Internet is 100% secure, and we cannot guarantee that unauthorized third parties will not defeat our security measures or use your Personal Information for improper purposes. 

International Data Transfers

Squarebit is owned and operated in the United States. If you visit the Site from outside of the United States, Personal Information we collect about you will be transferred to our servers in the United States and maintained there indefinitely. This may require the transfer of your Personal Information out of your country of origin with laws governing data collection and use that may differ from or be more restrictive than U.S. law, or may result in governments, courts, law enforcement or regulatory agencies having access to or obtaining disclosure of your Personal Information pursuant to the laws of the applicable foreign jurisdiction. By allowing us to collect Personal Information about you, you consent to the transfer and processing of your Personal Information as described in this paragraph.

Third Party Websites

The Site may contain links to websites owned or operated by third parties. We have no ability to control, and we are not responsible for, the privacy and data collection, use, and disclosure practices of third-party websites. We encourage you to read the privacy statements of each website that collects your Personal Information. 

Changes to this Privacy Notice

We may periodically update this Privacy Notice. If we make any material changes, we will notify you by updating this posting or by posting notice in the Site. The date that this Privacy Notice was last revised is identified at the top of the page. Your continued use of the Site after the effective date will be subject to the new Privacy Notice. You are responsible for periodically checking this Privacy Notice for changes.

Contact Squarebit

If you have questions about our privacy practices or would like to make a complaint, please contact us at contact@squarebitstudios.com.