RedShelf Privacy Notice

for California Residents

Effective Date: January 1, 2020

Last Reviewed on: December 27, 2019

 

This Privacy Notice for California Residents (the “California Privacy Notice”) supplements the information contained in RedShelf’s  Privacy Notice and applies solely to visitors, users, and others who reside in the State of California (”End Users” or “you”).  This California Privacy Notice applies to End Users of the RedShelf website (redshelf.com) (the “Website”) and the RedShelf eReader (the “eReader”, collectively with the Website, the “RedShelf Platform”). RedShelf, Inc. (“RedShelf” or “we”) has adopted this California Privacy Notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.  If you are an End User that purchased your digital content specifically from Follett or a Follett-affiliated bookstore or institution, you should make any CCPA inquiry through Follett, for whom we are a service provider.

Information We Collect

The RedShelf Platform collects information that identifies, relates to, describes, references, or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (”personal information”). In particular, the RedShelf Platform has collected the following categories of personal information from its  End Users within the past twelve (12) months:

A. Identifiers. (Collected)

Names, aliases, postal addresses, unique personal identifiers, online identifiers, Internet Protocol addresses, email addresses and if you are an eReader user, profile pictures, account names and RedShelf ID numbers. We do not collect your social security number.

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). (Collected)

A name, signature, address, telephone numbers and certain educational history.

 

We do not directly collect or store your payment information (such as debit or credit card information you may use at the time of purchase on the Website).  Rather, we use a third-party payment gateway service provider to complete that transaction and therefore we do not collect or maintain your full payment information within RedShelf. 

 

If you obtained your academic content through one of the higher education academic institutions we provide services to (a “RedShelf Academic Institution”), we may be aware of certain educational information about you, including the school you attend, the courses you are taking, the course materials you are using and potentially your student identification number. 

 

If you are a student using our eReader, our systems may collect certain metadata and usage information, (i) such as the content and pages you access, (ii) the dates, times and duration of your visits and usage of the eReader, (iii) navigation data (such as usage of certain eReader features, your opening and closing of menu’s), (iv) your actions and activity (such as searches, use of the dictionary lookups, creation of notes, flashcards, comments, printing, taking certain content off-line, etc.). We will also track your usage of content in the eReader to ensure your compliance with certain access rights associated with the content, including the duration of your access rights to certain content on the eReader, the amount of content you print or download to a device. We collect information on your logins to the eReader, including any failed logins.  For more information, please also see Section 2.1 (b) (Access Rights Information), (c) (User Content) and (d) (Metadata) in our Privacy Policy for more information of the types of usage data we collect related to your usage of the eReader.

 

Some personal information included in this category may overlap with other categories. 

 

C. Protected classification characteristics under California or federal law. (Collected)

We collect your date of birth, and so we may know if you are over 40 years of age.  We do not collect information about any physical or mental disability, but if you are a student at one of the RedShelf Academic Institutions we provide services to, we may become aware of a mental or physical disability of yours, if you or your academic institution reach out to RedShelf to assist in supporting your request for some sort of accessibility accommodation at your RedShelf Academic Institution.  RedShelf will actively work with students on the RedShelf Platform and the RedShelf Academic Institutions to support their various accessibility needs.

 

D. Commercial information. (Collected)

Records of  products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. RedShelf collects and maintains information about the content and materials you purchase on the Website.  As noted in (B) above, RedShelf also tracks a variety of usage information related to your usage of the eReader.

 

E. Biometric information. (Not Collected)

We do not collect any biometric information on you, such as genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

F. Internet or other similar network activity. (Collected)

Browsing history on the Website, search history on the Website, information on an End User’s interaction with our Website and use of the eReader.  We will collect information related to your hardware model, operating system, browser type and version, as well as your Internet Protocol address.  We will collect information about the dates, times and durations of your visits to our Website, We will place “cookies” on your browser, to better enable RedShelf to see how you are using or moving through our Website and improve your experience on our Website. We do not track your Internet usage on sites other than our Website.

 

As noted in (B) above, RedShelf also tracks a variety of usage information related to your usage of the eReader.

G. Geolocation data. (Collected)

We will collect information about your physical location related to your usage of the RedShelf Platform, generally tracking your IP addresses. We collect this information to mitigate against fraud and to ensure compliance with certain geographic limitations applicable to content accessed through our eReader. We may also collect your address in connection with delivery of certain physical goods. 

H. Sensory data. (Not Collected)

We do not collect audio, electronic, visual, thermal, olfactory, or similar information.

I. Professional or employment-related information. (Not Collected)

 We do not collect any current or past job history or performance evaluations related to you.

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). (Collected)

We may collect certain education records directly related to a student maintained by an educational institution or party acting on its behalf, such as, class lists, student schedules, student identification codes and student financial information.  We could receive some of this information from our RedShelf Academic Institutions we provide services to and which you may attend. 

K. Inferences drawn from other personal information. (Not Collected)

We do not collect profiles reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Personal information does not include:

  • Publicly available information from government records.

  • Deidentified or aggregated consumer information.

  • Information excluded from the CCPA’s scope, like:

  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;

  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

RedShelf obtains the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from forms you complete, from information you provide at the time you register on our Website or our eReader, such as your name, email address, date of birth, your phone number, billing address and a profile picture.  The information related to your content orders on the Website.  Information about a disability, if you reach out to RedShelf to aid in facilitating an accessibility request.

  • Indirectly from you. For example, from observing your actions on our Website and usage of the eReader mentioned above.  This includes the geo-location data and IP address information mentioned above.

  • From RedShelf Academic Institutions. If you obtain your eBooks or courseware through a RedShelf Academic Institution (whether via a bookstore or website) or directly from the institutions as part of an inclusive access program,  those RedShelf Academic Institutions (including their bookstores), may be providing us information about you, including your name, email address and certain of the educational information mentioned in J above (such as your student ID, course information, student aid information, etc.).  We may get certain personal information through our integrations with certain other service providers integrated with RedShelf Academic Institutions, in particular: (i)  point of sale providers integrated with academic bookstores, (ii) learning management systems providers and (iii) student information system providers.

  • RedShelf Publisher Partners.  RedShelf partners with numerous publishers to distribute their content to RedShelf Academic Institutions (which may also be accessed via the eReader) and we may get the following type of personal information from these publisher partners: transactional  information, student name, email, and certain school records (e.g., student ID, course selections).

  • Follett. RedShelf provides certain services to Follet and its affiliated academic institutions and may receive the following type of information related to students who obtain content through Follett: email, name and the relevant content obtained by the student.  RedShelf is a technology service provider to Follett.

 

We may use or disclose the personal information we collect for one or more of the following business purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to make a customer support inquiry, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to help process your payment and facilitate delivery. 

  • To allow you to set up a RedShelf eReader account, enabling you to access to the content you purchased via the Website or through a RedShelf Academic Institution, including all the features of the eReader.  We may also save your information to facilitate new product orders or process returns or your opting-out of content included in inclusive access programs managed by RedShelf Academic Institutions.

  • To provide, support, personalize, and develop our Website, the eReader, and our products and services generally.

  • To create, maintain, customize, and secure your account with us.

  • To reconcile transactions with RedShelf Academic Institution and publishing partners.

  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.

  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and customer inquiries, including any inquiries about the functionality of the eReader or related to e-commerce transaction on the Website. 

  • To help maintain the safety, security, and integrity of our Website, eReader, and  our other products and services and our databases and other technology assets, and our business generally.  This includes using information you provide us directly or indirectly to verify your identity upon every login into the eReader to mitigate fraud and ensure compliance with our agreements with our publisher partners, who provide the content distributed and accessed via the eReader.

  • For testing, research, analysis, and product development, including to develop and improve our Website, eReader and our other products, and services.

  • To comply with the Digital Millennium Copyright Act, as well as the use restrictions on the content accessed and used via our eReader, that are set by our publisher partners who create the content.

  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.

  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of RedShelf’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by RedShelf about our  End Users is among the assets transferred.

 

RedShelf will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice, including by providing you an update to this California Privacy Notice.  RedShelf does NOT sell your personal information.

 

Sharing Personal Information

RedShelf may disclose your personal information to a third party for a business purpose.  When we disclose personal information for a business purpose, we enter into a contract that describes the purpose. We share your personal information with the following categories of third parties:

  • Service providers. For example, we use Amazon Web Services to host our Website and eReader.  We also share certain personal information with certain vendors who provide us tools, services and solutions to allow us to better manage and operate our business, offer improved products and services and manage risk.  These vendors may have hosted or cloud-based solutions, where some of your personal information could reside.

  • RedShelf Academic Institutions. We share a variety of personal information with RedShelf Academic Institutions (including their bookstores) to (i) enforce and manage refund restriction and End-User opt-outs related to inclusive access programs, (ii) reconcile payment and invoicing matters and (iii) enable the account access to End-Users. We may also share certain eReader usage information with our RedShelf Academic Institutions and their professors.

  • RedShelf Publisher Partners. We share a variety of personal information with our Publishers we have agreements with for the following purposes: (i) to reconcile invoices, (ii) enable the distribution of content to End-Users, (iii) manage refund requests from End-users and inform publishers of such, (iv) provide information on any violation of the digital rights limitations related to the publishers content (such as off-line usage, term of content license, amount of printing, etc.) and (v) detecting and reporting any fraudulent behavior.

  • Point of Sale Providers. We share certain personal information with POS providers who are integrated with RedShelf Academic Institutions, who are integrated with RedShelf Academic Institution book stores to (i) enable for the sale of digital content through the book stores, (ii) manage and enforce refund requests through the bookstores (and their websites), (iii) reconcile invoices and (iv) enable for the secure access of accounts and transactions via the bookstore (and their websites).

  • Learning Management Service Providers. We  integrate with a variety of LMS service providers used by the RedShelf Academic Institutions, which are used by students to activate or access the content they have purchased via RedShelf (including access to content on the eReader) and used by RedShelf Academic Institutions to launch and manage inclusive access programs and generally manage their students’ access to and use of content (eBooks and courseware) purchased through and/or hosted/accessed via our eReader.  As such, RedShelf may share certain personal information with these Learning Management Service provider platforms to (i) enable access to content, (ii) manage refund requests and opt-outs of inclusive access by students, and (iii) provide End Users secure access to the RedShelf eReader.

  • Physical Distribution Providers.  RedShelf partners with certain third parties who help fulfill physical inventory purchases (such as physical book or other associated physical products related to a course at a RedShelf Academic Institution).  In order to enable for them to fulfill such orders, RedShelf may provide them certain personal information, including your name, address, email and physical shipping address. 

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose (as described above):

  • Category A: Identifiers.

  • Category B: California Customer Records Personal Information Categories.

  • Category C: Protected Classification Characteristics under California or Federal Law

  • Category D: Commercial Information.

  • Category F: Internet or Other Similar Network Activity.

  • Category G: Geolocation data.

  • Category J: Non-Public Education Information

 

We disclose your personal information for a business purpose to the following categories of third parties set forth above.

 

Sales of Personal Information

In the preceding twelve (12) months, we have NOT sold your personal information.

Your Rights and Choices under the CCPA

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

  • The categories of personal information we collected about you.

  • The categories of sources for the personal information we collected about you.

  • Our business or commercial purpose for collecting that personal information.

  • The categories of third parties with whom we share that personal information.

  • The specific pieces of personal information we collected about you (also called a data portability request).

  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

    • sales, identifying the personal information categories that each category of recipient purchased; and

    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.  Again, we do NOT sell your personal information.

Deletion Request Rights

You have the right to request that we delete your personal information that we collected from you and retained, subject to certain exceptions under the CCPA.  In particular, we may not delete certain personal information to the extent it is necessary to mitigate fraud, to enable compliance with our return policies and opt-outs of inclusive access programs at RedShelf Academic Institutions or to enable continued access to content an End-User may have access to on our eReader.  Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

 

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

  • Debug products to identify and repair errors that impair existing intended functionality.

  • Exercise free speech ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

  • Comply with a legal obligation.

  • Make other internal and lawful uses of that information that are compatible with the context in which you provided the personal information.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending an email request to the following email address:: Privacy@RedShelf.com.  

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

 

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us.

 

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

 

If you have an account with us, we will deliver our written response to an email associated with your account in our system. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

 

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

 

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. 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.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.

  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

  • Provide you a different level or quality of goods or services.

  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to Privacy@RedShelf.com or write us at: RedShelf, 500 N. Dearborn Ave, Suite 1200, Chicago, Illinois 60654 Attention:  General Counsel.

Changes to Our Privacy Notice

RedShelf reserves the right to amend this California Privacy Notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and with the eReader and update the notice’s effective date. Your continued use of our Website and eReader following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this California Privacy Notice, the ways in which we collect and use your information described above and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law (as a California resident), please do not hesitate to contact us at:

 

Email: Privacy@RedShelf.com

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