Legal

Privacy Policy Part I, Privacy Policy Part II, Privacy Policy Part III

Who we are

THENCE LLC can be visited at THENCE.us

Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Cookies

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Who we share your data with

If you request a password reset, your IP address will be included in the reset email.

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

What rights you have over your data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

PART II

The “JUST CHALK TO US” Webzine PRIVACY POLICY

Last update:27 October 2022

This privacy policy explains you how we collect, use, and disclose your personal data when you use this blog. It also informs you about the choices that you have with respect to your personal data. Please read the privacy policy carefully.

1. ABOUT US AND THE THENCE BLOG 1

2. WHAT DATA DO WE COLLECT? 2

3. HOW LONG DO WE STORE YOUR DATA? 4

4. HOW DO WE DISCLOSE YOUR DATA? 4

5. HOW DO WE PROTECT YOUR DATA? 5

6. HOW CAN YOU MANAGE YOUR PERSONAL DATA? 6

7. COOKIES AND ADVERTISING 7

8. CONTACT 9

1. ABOUT US AND THE THENCE BLOG

In this section, we provide you with general information about us andthe THENCE Blog.

1.1 About. This privacy policy (the “Privacy Policy”) governs the processing of personal data collected from individual users (“you” and “your”) through the website https://justchalk2.us, the related software and domain names (collectively, the “THENCE Blog”).

1.2 About the THENCE Blog. The THENCE Blog offers information in the field of education and provides an overview of our services.

1.3 Data controller.  The entity that owns the THENCE Blog is Thence LLC, having an address at 4000 Royal Marco Way, Unit 426, Marco Island FL 34145-1839, the United States (“we,” “us,” and “our”). We act as a data controller with regard to the personal data that you submit through the THENCE Blog.

1.4 Third-party websites. The Privacy Policy does not cover any third-party websites, applications or software that integrate with the THENCE Blog. We are not responsible for the privacy policies of websites to which the THENCE Blog links. If you provide any information to such third parties different rules regarding the collection and use of your personal data may apply. You should contact these entities directly if you have any questions about their use of the data that they collect.

1.5 Children. The THENCE Blog is not intended for use by persons under the age of 18. We do not knowingly collect personal data belonging to persons younger than 18. If you become aware that such a person has provided us with his or her personal data and you are a parent or a legal guardian of that person, please contact us immediately and we will remove the child’s personal data from our systems.

1.6 Term and termination. This Privacy Policy enters into force on the effective date indicated at the top of the Privacy Policy and remains valid until terminated or updated by us.

1.7 Amendments. This Privacy Policy can be changed or updated occasionally to meet the requirements and standards. Therefore, you are encouraged to frequently visit this page to be updated about the changes. Such modifications will be effective on the day they are posted. The amended version of the Privacy Policy will be posted on this page and, if we have your email address, we will send you a notice about all the changes implemented by us. For significant material changes in the Privacy Policy or, where required by the applicable law, we may seek your consent.

2. WHAT DATA DO WE COLLECT?

In this section, we explain in detail what personal data we collect from you, for what purposes we use it, what technical data is collected automatically when you use the THENCE Blog, and how we communicate with you.

2.1 Sources of personal data. We obtain your personal data from the following categories of sources:

• Directly from you. For example, if you need to register a user account with us or contact us;
• Directly or indirectly through your activity on the THENCE Blog. When you use the THENCE Blog, we automatically collect technical information about your visits by means of cookies and analytics services; and
• From third parties. We may receive information about you from third parties to whom you have previously provided your personal data, if those third parties have a legal basis for disclosing your personal data to us (for example, for analytics purposes).

2.2 Collection of personal data. We comply with data minimisation principles. This means that we collect only a minimal amount of personal data that is necessary for your use of the THENCE Blog. We use your personal data for limited, specified and legitimate purposes explicitly mentioned in this Privacy Policy. We do not repurpose your personal data. This means that we do not use it for any purposes that are different from the purposes for which your personal data was provided. Below, you can find an overview of the types of personal data that we collect, the purposes for which we use it, and the legal bases on which we rely when processing it.

• Account. When you need to register an account (for example, in order to contribute to the THENCE Blog or access certain content) , you need to contact us and we will do this for you. In order to register your account, we may ask you a username and email address. We will use this information to register and maintain your user account, enable you to contribute or access content (whichever applicable), contact you, if necessary, and maintain our business records. The legal bases on which we rely are ‘performing a contract with you’ and ’pursuing our legitimate interests’ (i.e., operate, analyze, grow, protect, and administer the THENCE Blog). We will store account data until you delete your account.
• Enquiries. When you contact us, we collect your name, email address, and any information that you decide to include in your message. We use such data to respond to your enquiries and provide you with the requested information. The legal bases on which we rely are ‘pursuing our legitimate interests’ (i.e., to grow and promote the THENCE Blog) and ‘your consent’ (for optional personal data). We will store this data until you stop communicating with us.
• Your content. When you post any content on the THENCE Blog (for example, forum posts, files, photos, links, and reviews), such content may contain personal data that you decide to share. Please note that the provision of personal data in this context is at your sole discretion. Therefore, we ask you to exercise due diligence when disclosing your or other person’s personal data. Please note that you are not allowed to disclose other individuals’ personal data without their consent.  If your content features any personal data, we will process it on the ’pursuing our legitimate interests’ basis (i.e., ensure the functioning of the THENCE Blog) and keep it as long as your user account is active, unless you decide to delete the content earlier. 

2.3 Cookies. When you browse the THENCE Blog, we collect your cookie-related data and use other tracking technologies as described in detail in section 7 “Cookies and Advertising.”

2.4 Sensitive data. We do not collect or have access to any special categories of personal data (“sensitive data”) from you, unless you decide, at your own discretion, to provide such data to us. Sensitive data refers to your health, religious and political beliefs, racial origins, membership of a professional or trade association, or sexual orientation.   

2.5 Refusal to provide personal data. If you refuse to provide us with your personal data when we ask for it, we may not be able to perform the requested operation and you may not be able to use the full functionality of the THENCE Blog, receive the requested information, or get our response. Please contact us immediately if you think that any personal data that we collect is excessive or not necessary for the intended purpose. 

2.6 Collection of analytics data. When you browse the THENCE Blog, we collect certain technical analytics data collected from you. Such data includes the following information:

• URL addresses from which you access the THENCE Blog;
• Device type;
• Operating system;
• Interactions per visit;
• Exit pages;
• Bounce rates;
• Conversion rates;
• IP address; and
• Your other online behavior.

2.7 Purposes of analytics data. We use your analytics data to analyze what kind of users access and use the THENCE Blog, measure your engagement with the THENCE Blog, see which parts of the THENCE Blog are interesting to you, develop new features of the THENCE Blog and our content, and investigate and prevent security issues and abuse. In most cases, such analytics data is non-personal and it does not allow us to identify you as a natural person. However, your IP address may be considered personal data and we will make sure that we have the necessary legal basis for processing such data. When we process your analytics data that is personal data, we rely on the ‘legitimate interest’ (i.e., to analyze, improve, and protect the THENCE Blog) and ‘your consent’ bases.

2.8 Your feedback. If you contact us, we may keep records of any questions, complaints, recommendations, or compliments made by you and the response. Where possible, we will de-identify your personal data (i.e., we will remove all personal data that is not necessary for keeping such records).

2.9 Aggregate and de-identified data. In case your non-personal data is combined with certain elements of your personal data in a way that allows us to identify you, we will handle such aggregate data as personal data. If your personal data is aggregated or de-identified in a way that it can no longer be associated with an identified or identifiable natural person, it will not be considered personal data and we may use it for any legitimate purpose.

2.10 Newsletters. When you subscribe for our newsletter, we will inform you about our new content and special offers. The legal basis on which we rely is ‘your consent’. You can opt-out from receiving our commercial communication at any time free of charge by clicking on the “unsubscribe” link included in our newsletters or by contacting us directly.

2.11 Transactional notices. If we have your email address and it is necessary to do so, we may send you important informational messages, such as order confirmations and updates, requests for more information, and other technical or administrative emails. Please note that such messages are sent on an “if-needed” basis and they do not fall within the scope of commercial communication that may require your prior consent. You cannot opt-out from service-related notices.

3. HOW LONG DO WE STORE YOUR DATA?

In this section, we explain for how long we keep your data in our systems and how we delete it.

3.1 Storage of personal data. We and our data processors store your personal data only for as long as such personal data is required for the purposes described in this Privacy Policy or until you request us to update or delete your personal data, whichever comes first. For more details about the period for which each type of personal data is stored, please refer to section 2.2. After your personal data is no longer necessary for its purposes and there is no other legal basis for storing it, we will immediately securely delete your personal data from our systems. We do not store any personal data longer than strictly necessary.

3.2 Storage of non-personal data. We retain non-personal data pertaining to you for as long as necessary for the purposes described in this Privacy Policy. This may include storing non-personal data for the period of time needed for us to examine our activities, fulfil our contractual obligations, pursue our legitimate interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

3.3 Storage as required by law. In very seldom cases, we may be obliged by law to store your personal data for a certain period of time. If such a requirement exists, we will store your personal data for the time period stipulated by the applicable law and delete the personal data as soon as the required retention period expires.

4. HOW DO WE DISCLOSE YOUR DATA?

In this section, you can find information about third parties that may have access to your personal data.

4.1 Disclosure to data processors. We keep your personal data in strict confidentiality. However, if necessary for the intended purpose of your personal data, we will disclose your personal data to entities that provide services on our behalf (our data processors). Your personal data may be shared with entities that provide technical support services to us, such as hosting, payment processing, and email distribution services. We do not sell your personal data to third parties and do not intend to do so in the future. The disclosure of your personal data is limited to the situations when it is required for the following purposes:

• Ensuring the proper operation of the THENCE Blog;
• Responding to your enquiries;
• Pursuing our legitimate interests;
• Enforcing our rights, preventing fraud, and security purposes;
• Carrying out our contractual obligations;
• Law enforcement purposes; or
• If you provide your prior consent to such a disclosure.

4.2 List of data processors. We choose our data processors carefully and make sure that they ensure an adequate level of protection of personal data that is consistent with this Privacy Policy and the applicable data protection laws. The data processors that will have access to your personal data are:
 

• Our web hosting service provider ______ located in ______;
• Our cloud storage service provider ______ located in ______;
• Our marketing service provider ______ located in ______;
• Our mailing service provider ______ located in ______;
• Our CRM service provider Zoho (https://www.zoho.com/) located in India;
• Our business management software service provider Odoo (https://www.odoo.com/) located in Belgium;
• Our analytics service provider Google Analytics (https://analytics.google.com) located in the United States; and
• Our independent contractors and consultants.

4.3 International transfers. Some of our data processors may be based outside the country where you reside.For example, if you reside in a country belonging to the European Economic Area (EEA), we may need to transfer your personal data outside the EEA. In case it is necessary to make such a transfer, we will make sure that the country in which our data processor is located guarantees an adequate level of protection for your personal data or we conclude an agreement with it that ensures such protection (e.g., a data processing agreement based pre-approved Standard Contractual Clauses).

4.4 Disclosure of non-personal data. Your non-personal data may be disclosed to third parties for any purpose as it does not identify you as a natural person. For example, we may share it with prospects or partners for business or research purposes, for improving the THENCE Blog, responding to lawful requests from public authorities or developing new products and services.

4.5 Legal requests. If requested by a public authority, we will disclose information about the users of the THENCE Blog to the extent necessary for pursuing a public interest objective, such as national security or law enforcement.

5. HOW DO WE PROTECT YOUR DATA?

Here you can find information on how we protect your data against breaches.

5.1 Security measures. We implement technical and organizational information security measures   that protect your personal data from loss, misuse, unauthorized access and disclosure. The security measures taken by us include secure Swiss servers, encryption, proper authentication, secured networks, strong passwords, limited access to your personal data by our staff, anonymisation of personal data (when possible), and carefully selected data processors.

5.2 Security breaches. Although we put our best efforts to protect your personal data, given the nature of communication and information processing technology and the Internet, we cannot be liable for any unlawful destruction, loss, use, copying, modification, leakage, and falsification of your personal data caused by circumstances that are beyond our reasonable control. In case a serious breach occurs, we will take reasonable measures to mitigate the breach, as required by the applicable law. Our liability for any security breach will be limited to the highest extent permitted by the applicable law.

6. HOW CAN YOU MANAGE YOUR PERSONAL DATA?

Here you can find detailed information about the rights that you have with regard to your personal data and how to exercise those rights.

6.1 The list of your rights. You have the right to control how we process your personal data.Subject to any exemptions provided by law, you have the following rights:

• Right of access: you can get a copy of your personal data that we store in our systems and a list of purposes for which your personal data is processed;
• Right to rectification: you can rectify inaccurate personal data that we hold about you;
• Right to erasure (‘right to be forgotten’): you can ask us to erase your personal data from our systems;
• Right to restriction: you can ask us to restrict the processing of your personal data;
• Right to data portability: you can ask us to provide you with a copy of your personal data in a structured, commonly used and machine-readable format and move that personal data to another processor;
• Right to object: you can ask us to stop processing your personal data;
• Right to withdraw consent: you have the right to withdraw your consent, if you have provided one; or
• Right to complaint: you can submit your complaint regarding our processing of your personal data.

6.2 How to exercise your rights? If you would like to exercise any of your legitimate rights, please contact us by using our contact details available at the end of the Privacy Policy and explain in detail your request. In order to verify the legitimacy of your request, we may ask you to provide us with an identifying piece of information, so that we can identify you in our system. We will answer your request within a reasonable time frame but no later than 30 days.

6.3 Complaints. If you would like to launch a complaint about the way in which we handle your personal data, we kindly ask you to contact us first and express your concerns. After you contact us, we will investigate your complaint and provide you with our response as soon as possible (no later than 30 days). If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.

7. COOKIES AND ADVERTISING

7.1 We use cookies on the THENCE Blog in order to analyze the technical aspects of your use of the THENCE Blog, conduct our marketing campaigns, prevent fraud and abuse, and ensure the security of the THENCE Blog. The legal bases on which we rely are ‘pursuing our legitimate interests’ (i.e., analyze our content and protect the THENCE Blog) and ‘your consent’. Unless cookies expire earlier, we store this data as long as analytics records are necessary for our activities or you withdraw your consent.

7.2 We may use different types of cookies on the THENCE Blog, including:

• Essential technical cookies that are strictly necessary to ensure the correct functioning of the THENCE Blog and provide the services requested by you;
• Preference cookies that allow us to save and preserve your preferences;
• Marketing cookies that allow us to create, implement, and examine our marketing campaigns. Such cookies allow us to reach the right customers, analyse the productivity of our marketing campaigns, and offer you personalised advertisement; and
• Statistics cookies that allow us to generate statistical reports about how you use the THENCE Blog.
   

7.3 Cookie consent. When you visit the THENCE Blog, we may ask you to provide us with your consent to our use of all cookies via a cookie consent banner (for example, if we see that you are based in the EU). If you do not provide your opt-in consent, we will not serve you our non-essential (statistics, marketing, and advertising) cookies. Please note that we may not be able to provide you with the best possible user experience if not all cookies are enabled.

7.4 Disabling cookies. When we ask you to provide your consent to our use of non-essential cookies, you have the freedom not to provide such consent. If you would like to refuse our use of non-essential cookies later, you can do it at any time by declining cookies in your browser or device. For more information, you can consult the cookie management instructions of your browser:

• Apple Safari: https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac
• Google Chrome: https://support.google.com/chrome/answer/95647 
• Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences 
• Opera: https://blogs.opera.com/news/2015/08/how-to-manage-cookies-in-opera/ 
• Microsoft Edge: https://support.microsoft.com/en-us/help/4468242/microsoft-edge-browsing-data-and-privacy-microsoft-privacy

7.5 Targeted Advertising. You may encounter targeted interest-based advertising based on your use of the THENCE Blog and other websites on the Internet. We use Google Ads that deliver such services. Such advertising may also be based on profiling that automatically groups the users of the THENCE Blog. Where necessary, we will seek your consent (for example, for the use of non-essential advertising cookies). You can control how such advertising is shown to you or opt-out from targeted advertising by consulting the guide powered by the Digital Advertising Alliance available at https://youradchoices.com. For more information on opting-out from advertising features on your device, please visit https://www.networkadvertising.org. Where interest-based advertising uses non-essential cookies, we will ask your consent for such cookies. Also, you may adjust the settings of your Google account to manage the advertising content that you are served.

7.6 Google Analytics. We use Google Analytics, a web analytics service provided by Google LLC registered at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google generates statistical information by means of cookies and creates reports about your use of the THENCE Blog. The cookies served by Google are anonymous first-party cookies that do not allow us to identify you in any manner. The information generated by cookies will be transmitted to and stored by Google on servers in the United States. To ensure your privacy, your IP address will be anonymised and Google will not combine your IP address with other information Google holds about you. Thus, Google will not be able to identify you. In certain cases (e.g., when required by law or when third parties conduct services on behalf of Google), Google may transfer the information to third parties. For more information about Google Analytics’ privacy practices, please visit https://support.google.com/analytics/answer/6004245. If you would like to opt out from Google Analytics, you can do so by installing a Google Analytics opt-out browser add-on available at https://tools.google.com/dlpage/gaoptout?hl=en. We will ask you to provide us with your consent for non-essential Google Analytics cookies through a cookie consent banner. If you do not provide such consent, we will not use Google Analytics to analyse your use of the THENCE Blog.
 

7.7 List of cookies. Below, you can find a list of cookies that we use on the THENCE Blog, including their purpose and expiration time:

Essential technical cookies
Name	Provider(location)	Expiration	Purpose
H5PUserUUID	justchalk2.us (Switzerland)	Persistent	This cookie allows functionalities in interactive games by tracking the user’s ID and their scores, as well as our ability to ask valid questions.
Preference cookies
Name	Provider(location)	Expiration	Purpose
	THENCE Sagl /Infomaniak	Persistent	To make sure users preferences are maintained.
Statistics cookies
Name	Provider(location)	Expiration	Purpose
	THENCE Sagl /Infomaniak	Persistent
Marketing and advertising cookies
Name	Provider(location)	Expiration	Purpose
	ZOHO (India)	Persistent
Unclassified cookies
Name	Provider(location)	Expiration	Purpose
	THENCE Sagl /Infomaniak

8. CONTACT

If you have any questions about this Privacy Policy, your rights, or our data protection practices, please contact us by using the following contact details:

Email:info@justchalk2.us