EU-U.S. and Swiss-U.S. Privacy Shield Policy Notice

Pedago, LLC. (“We” or “Our”), dba Smartly, Smartly Institute, Smartly School of Professional Education, Quantic, Quantic School of Business and Technology, Valar, Valar Institute, has certified with the EU-U.S. and Swiss-U.S. Privacy Shield with respect to the personal data we receive and process on behalf of our customers through our online platform (the “Services”). Pedago certifies that it adheres to the Privacy Shield Principles for Personal Data received from entities in the European Economic Area (the “EEA”), United Kingdom, and Switzerland. This Privacy Shield Policy, in conjunction with our Privacy Policy (available here) describe the privacy practices we implement for any customer data collected worldwide. This Privacy Shield Policy uses terms defined in our general Privacy Policy.

To learn more about the Privacy Shield program visit www.privacyshield.gov, and to view our certification, please visit https://www.privacyshield.gov/list.

Data Collected

We only collect Personal Data that is relevant to providing our Services. Examples of the types of personal data collected can be found in our full privacy policy. We take reasonable steps to ensure that the Personal Data received under the Privacy Shield is needed for Pedago’s Services, and that it is accurate, complete, and current based on the information you have provided to us.

Data Security

We use reasonable and appropriate physical, electronic, and administrative safeguards to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction, taking into account the nature of the Personal Data and the risks involved in processing that information.

Access to Personal Data

You may contact us at [email protected] to review, correct, or delete any personal data. We may limit or deny access to Personal Data where providing such access is unreasonably burdensome, expensive under the circumstances, or as otherwise permitted by the Privacy Shield Principles.

We process Customer Data submitted by customers for the purpose of providing the Services to customers. To fulfill these purposes, we may access data to provide the Services, to prevent or address service or technical problems, to respond to customer support matters, to follow the instructions of our customer who submitted the data, or in response to contractual requirements with our customers. 

Third-Party Data Sharing

We may share your data with a limited number of third-party providers as outlined in our privacy policy. If we receive personal data subject to our certification under the Privacy Shield, and then transfer it to a third-party service provider acting as an agent on our behalf, we have certain liability under the Privacy Shield if both (i) the agent processes the personal data in a manner inconsistent with the Privacy Shield and (ii) we are responsible for the event giving rise to the damage.

You have the ability to limit the disclosure of your data to third parties for purposes that are unrelated to the Services. To opt out of such disclosure to third parties, please contact us at [email protected].

Your Choices Regarding Information

You have several choices regarding the use of information on our Service:
  1. Email Communications. We will periodically send you free newsletters and emails that directly promote the use of our Site or Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the email you receive or by contacting us directly (please see contact information below). Despite your indicated email preferences, we may send you service related communications, including notices of any updates to our Terms of Use or Privacy Policy.
  2. Cookies. If you decide at any time that you no longer wish to accept Cookies from our Service for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to use all portions of the Service or all functionality of the Service. If you have any questions about how to disable or modify Cookies, please let us know at the contact information provided below.
  3. De-Linking SNS. If you decide at any time that you no longer wish to have your SNS account (e.g., Facebook) linked to your Account, then you may de-link the SNS account in the “preferences” section in your account settings. You may also manage the sharing of certain Personal Data with us when you connect with us through an SNS, such as through Facebook Connect. Please refer to the privacy settings of the SNS to determine how you may adjust our permissions and manage the interactivity between the Services and your social media account or mobile device.
  4. Changing or Deleting Your Personal Data. You may change any of your Personal Data in your Account by editing your profile within your Account or by sending an e-mail to us at [email protected]. You may request deletion of your Personal Data by us, and we will use commercially reasonable efforts to honor your request, but please note that we may be required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We may also retain your information for fraud or similar purposes.
  5. Applications. You can stop all collection of information by the Application by uninstalling the Application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.

Questions or Complaints:

If you are a resident of a European country participating in the Privacy Shield and you believe we do not maintain your personal data within the scope of this Privacy Shield certification, you may direct any questions or complaints concerning our Privacy Shield compliance to [email protected] or contact us at our mailing address:

Pedago LLC dba Valar Institute
712 H Street NE Suite 1802
Washington, DC 20002

We will work with you to resolve your issue.

Dispute Resolution

In the event we are unable to resolve your concern, you may contact JAMS, which provides an independent third-party dispute resolution body based in the United States, and they will investigate and assist you free of charge. A binding arbitration option may also be available to you in order to address residual complaints not resolved by any other means.

Arbitration

You may also be able to invoke binding arbitration for unresolved complaints, but prior to initiating such arbitration, a resident of Switzerland or a European country participating in the Privacy Shield must first: (1) contact us and afford us the opportunity to resolve the issue; (2) seek assistance from JAMS; and (3) contact the U.S. Department of Commerce (either directly or through a European Data Protection Authority) and afford the Department of Commerce time to attempt to resolve the issue. If such a resident invokes binding arbitration, each party shall be responsible for its own attorney’s fees. Please be advised that, pursuant to the Privacy Shield, the arbitrator(s) may only impose individual-specific, non-monetary, equitable relief necessary to remedy any violation of the Privacy Shield Principles with respect to the resident.

U.S. Federal Trade Commission Enforcement

Our Privacy Shield compliance is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

Requirement to Disclose

We may disclose personal data when we have a good faith belief that such action is necessary to: conform to legal requirements or to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements; or to enforce our contractual obligations.

Changes to This Policy

We may make changes to this policy from time to time in conjunction with our privacy policy and in compliance with the Privacy Shield. You can refer to the most recent revision date (labeled as "Last updated on") at the bottom of this policy.

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