PRIVACY POLICY



Please read our Terms of Service and this Privacy Policy carefully, as you must agree to both documents in order to be permitted to use our Services. This Privacy Policy governs your use of the website under the domain name http://trueshelf.com (“Site”), the software application entitled “TrueShelf” (the “App”) and related services available or accessible through the Site and App (the “Services”) that are offered by TrueShelf Inc. (“TrueShelf” or “Company” or “We” or “Us”).

This Privacy Policy describes the information we collect from you, how we use and disclose such information, and the steps we take to protect your information. By using the Services, you consent to the privacy practices described herein. Please note that this Privacy Policy is incorporated into and is subject to the TrueShelf Terms of Use Agreement (“Terms”). Capitalized terms that are not defined in the Privacy Policy have been given meaning and defined in the Terms.

For purposes of this Privacy Policy and our Terms, the phrases “Individual Customer” or “customers that are individuals”, means an individual or family who has directly purchased TrueShelf Services for personal or family use and “School Customer” means and educational institution or teacher that has purchased our Services and provides accounts to individual student users.

1. COLLECTION AND USE OF PERSONAL INFORMATION. Depending on how you use the Services, we may ask you to share personally identifiable information (“Personal Information”) with us. Whether you choose to share your Personal Information is completely up to you, but keep in mind that you will not be able to access some areas of the Service or effectively use the services we offer on the Services without sharing Personal Information. Personal Information includes any information that identifies or can be used to identify, contact or locate you. Examples include your full name, email address, age, screen name/user identification, password, school, grade level, location, title (teacher, parent, student), and credit card information. See below for details on the information we collect from users:

2. USE OF COOKIES. As a standard practice, TrueShelf uses “cookies” – a small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services. Persistent cookies can be removed. Please review your web browser “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete, or choose not to accept, cookies from our Services, you may not be able to utilize the features of the Services to their fullest potential.

3. THIRD PARTY AND INTERNAL ANALYTICS FRAMEWORKS. We currently use the following three analytics tools in addition to the aforementioned data we collect: StatCounter, Flurry Analytics, and our internal website usage analytics developed by TrueShelf.

  1. StatCounter: StatCounter records users’ anonymous webpage activity and sends them to TrueShelf. StatCounter offers us statistics on any of the following: Configurable Summary Stats, Popular Pages, Entry Pages, Exit Pages, Keyword Analysis, Recent Keyword Activity, Visitor Paths, Visit Length, Returning Visits, Recent Pageload Activity, Recent Visitor Activity, Country/State/City Stats, Recent Visitor Google Map, Browser Stats, O.S. Stats, Resolution Stats, JavaScript Stats, Email Reports, Multiple Site Management, and Public Stats.
  2. Flurry Analytics: The Flurry Analytics SDK provides TrueShelf with data to help us gain a deep level of understanding about our users’ behavior in our apps. The analytic framework is set up through advanced analysis of complex events, with metrics, segments and funnels to track our users’ habits and performance.
  3. Internal Analytics: Similar to StatCounter and Flurry Analytics, TrueShelf has developed its own internal analytic framework that will help us gather information primarily about user activity/behavior so that we may better improve our Services.


  4. 4. INFORMATION TRUESHELF COLLECTS DIRECTLY FROM YOUR STUDENT. TrueShelf collects information directly from your student, over the internet, in the form of the interactions that your student makes when participating in the Services. We refer to the data resulting from such participation, which includes but is not limited to data on when your student starts and stops a lesson, the responses your student makes to questions asked, the timing of your student’s responses, your student’s choice of character and customizations, and whether your student is answering questions correctly or incorrectly (collectively, “Performance Data”).

    We will use Performance Data to (1) measure your student’s performance in each lesson of our Services and to adapt the Services to his or her learning needs, (2) analyze your student’s Performance Data, and provide you with periodic feedback about your student’s performance in the Services, and (3) improve the Services. All such Performance Data is strictly accessible by the student, teacher, or their parents.

    If we ever need to collect information that is not Performance Data directly from a student, TrueShelf will seek express authorization of a parent or guardian prior to collecting such additional information from the student. In addition, we may aggregate your student’s Performance Data with the Performance Data of other students participating in the Services for marketing and other business related purposes. Aggregate information will be ANONYMOUS and will not identify your student or be combined with other information that would allow individual students to be identified.

    5. OPTING-OUT OF PROVIDING THE INFORMATION WE REQUEST. Because our Services are individualized and customized for each student, all the information we request from you and your student is required for you and your student to participate in the Services, with the exception of certain information to be used for our marketing purposes to you only. At any time, you may revoke your consent to allowing your student to participate in our Services or refuse to allow TrueShelf to further use or collect your student’s Personal Information. Any ANONYMOUS performance data will be retained, but we will no longer use any identifiable information regarding you or your student that you have provided. However, if you do any of the foregoing, you and your student will not be able to use or access the Services.

    6. REVIEWING AND CHANGING YOUR INFORMATION. You may review and modify your Registration Information at any time by accessing our website using your password.

    7. CONSENT. In order to use the Services, you will be asked to submit certain personal information about your student and you and to authorize TrueShelf to use that information in a limited number of ways. For our Individual Customers, if you are a parent or legal guardian of a student that will use TrueShelf, we will require you to review and submit a Parental Consent as part of the registration process, which will require you to consent to our collection and use of information directly from your student over the Internet as described above.

    8. PASSWORD PROTECTION. You will be asked to select a password to access the Services through our website, and this password will be used to allow your student to use the Services. Your password should be kept confidential. Your password will also allow you to review and change the information we collect about you and your student or students.

    9. PROTECTING YOUR INFORMATION. No data transmissions over the internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk. TrueShelf has multiple security measures in place to protect the loss, misuse or alteration of information under our control.

    Please note that this Service is hosted in the United States. If you are visiting from the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring your personal data to the United States, which does not have the same data protection laws as the EU or other regions; by providing your personal data you consent to the use of your personal data for the uses identified above in accordance with this Privacy Policy and the transfer of your personal data to the United States as indicated above.

    10. MERGERS & ACQUISITION. You should be aware that Personal Information may be transferred to a third party as a result of a sale, acquisition, merger, reorganization or other transfer involving TrueShelf. We specifically reserve the right to transfer Registration Information to a third party in connection with such a transfer. Should such a transfer occur, we will use our best efforts to require that the new combined entity follow our Privacy Policy with respect to your personally identifiable information.

    TrueShelf reserves the right to modify this policy at any time, so please review it frequently. In the event that a change to the Privacy Policy materially modifies your rights or obligations, you will be required to accept such modified terms in order to continue to use the Services. Modifications are effective upon your use or access of the Site, App, and/or Services immediately following publication. Disputes arising hereunder will be resolved in accordance with the Privacy Policy in effect at the time the dispute arose.

    11. UNSOLICITED THIRD-PARTY PROMOTIONAL EMAILS. The Services may contain features or links to websites and services provided by third parties. Any personally identifiable information you provide on third party sites or services is provided directly to that third party and is subject to that third party’s policies, if any, governing privacy and security, even if accessed through the Services. We are not responsible for the content or privacy and security practices and policies of third party sites or services to which links or access are provided through the Services. We encourage you to learn about third parties’ privacy and security policies before providing them with personally identifiable information.

    12. CHILDREN'S ONLINE PRIVACY PROTECTION ACT. For our Individual Customers or parents or legal guardians of a student:  Congress has enacted a law called the Children’s Online Privacy Protection Act of 1998 (COPPA) that is designed to protect children’s privacy during use of the Internet. TrueShelf has implemented practices consistent with the guidelines provided by the Federal Trade Commission to date. 
TrueShelf will never knowingly request, obtain, use or disclose personally identifiable information or private content from anyone under the age of 13 without parental consent. For our customers who are individuals, if you sign up for our Services, provided you are 18 years of age or older, you will be asked, at the time of registration, whether you consent to allowing users under the age of 13 to use your subscription and to be subject to this Privacy Policy. You must be the parent or legal guardian to grant such consent. If we receive this parental consent, we may receive personal information from children under the age of 13 listed on your subscription account in order to provide our Services and services to them. TRUESHELF DOES NOT SHARE CHILDREN’S PERSONAL INFORMATION WITH THIRD PARTIES.

    If you are a parent or legal guardian of a user under 13 you may, at any time, revoke your consent to allow your student to use the Services under your subscription, refuse to allow TrueShelf to further use or collect your student’s personal information, or direct TrueShelf to delete all identifiable information regarding your student that you have provided. To do so, please contact our support team at the contact information listed in Section 16. However, if you violate any Terms or policies, your student will not be able to use the Services.

    For administrative officials of our School Customers, to the extent that TrueShelf collects, uses, or discloses personal information from children under the age of 13, it is done in strict accordance with this Privacy Policy and for the sole purpose of providing services to the School Customer and student user. If you would like more information about COPPA, please go to http://www.ftc.gov/ogc/coppa1.htm.

    13. THE CHILDREN'S INTERNET PROTECTION ACT. The Children’s Internet Protection Act (CIPA) is a federal law enacted by Congress in December 2000 to address concerns about access to offensive content over the Internet on school and library computers. CIPA imposes certain types of requirements on any school or library that receives funding support for Internet access or internal connections from the “E-rate” program — a program that makes certain technology more affordable for eligible schools and libraries. Our Services do not provide links to external resources or chat rooms, and do not contain any offensive or inappropriate material. If you would like more information about CIPA, please go to http://www.fcc.gov/cgb/consumerfacts/cipa.html.

    14. THE FAMILY EDUCATIONAL RIGHTS AND PRIVACY ACT. For our School Customers:  The Family Educational Rights and Privacy Act (FERPA) is a Federal law that protects the privacy of student education records. The law applies to all schools that receive funds under an applicable program of the U.S. Department of Education.

    FERPA gives parents certain rights with respect to their children’s education records. These rights transfer to the student when he or she reaches the age of 18 or attends a school beyond the high school level. TrueShelf helps our School Customers be compliant with FERPA. Specifically:
    1. Any sensitive online information is transmitted over secure channels
    2. All student data are stored in ways that are not publicly accessible
    3. Security audits are regularly performed to ensure data integrity

    TrueShelf does not share information with any third parties that could be used to personally identify students. If a school requests that student data be sent to a third party, with parental consent, TrueShelf will send the data to the school and never directly to the third party. If you would like more information about FERPA, please visit http://www.ed.gov/policy/gen/guid/fpco/ferpa/index.html.

    15. MODIFICATIONS. TrueShelf may amend this Privacy Policy from time to time. We will notify you by popup regarding any material changes to our privacy and security practices. Please review all revisions to the Privacy Policy. Your continued use of our Services after the date TrueShelf has shown popup notifications will be deemed to be your agreement to the changed terms.

    16. CONTACT US. If you have any questions about your privacy or security measures at TrueShelf, please contact us at support@trueshelf.com.