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update privacy policy to October 5, 2020 copy
This commit is contained in:
Christopher Willis-Ford
parent
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commit
10b2bae670
1 changed files with 209 additions and 34 deletions
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@ -5,55 +5,230 @@ import styles from './privacy.css';
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const PrivacyElement = () => (
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<div className={styles.privacyBox}>
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<h1>Privacy Policy</h1>
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<i>The Scratch Privacy Policy was last updated: October 5, 2020</i>
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<p>
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We understand how important privacy is to our community, especially children and their parents. We wrote
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this privacy policy to explain what information we collect through the Scratch application (the
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“App”), how we use it, and what we're doing to keep it safe. If you have any questions
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regarding this privacy policy, you can <a
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The Scratch Foundation (“Scratch”, “we” or “us”) understands how
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important privacy is to our community. We wrote this Privacy Policy to explain what Personal Information
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(“Information”) we collect through our offline editor (the “<a
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href="https://scratch.mit.edu/download"
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target="_blank"
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rel="noopener noreferrer"
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>Scratch App</a>”), how we use, process, and share it, and what we're doing to keep it safe. It
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also tells you about your rights and choices with respect to your Personal Information, and how you can <a
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href="https://scratch.mit.edu/contact-us/"
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target="_blank"
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rel="noopener noreferrer"
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>contact us</a>.
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>contact us</a> if you have any questions or concerns.
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</p>
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<h2>What information does the App collect?</h2>
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<h2>What Information Does Scratch Collect About Me?</h2>
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<p>
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The Scratch Team is always looking to better understand how Scratch is used around the world. To help
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support this effort, Scratch only collects anonymous usage information from the Scratch App. This
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information does not include any Personal Information. For purposes of this Privacy Policy, “Personal
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Information” means any information relating to an identified or identifiable individual.
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For the purpose of this Privacy Policy, “Information” means any information relating to an
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identified or identifiable individual. The Scratch App automatically collects and stores locally the
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following Information through its telemetry system: the title of your project in text form, language
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setting, time zone and events related to your use of the Scratch App (namely when the Scratch App was
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opened and closed, if a project file has been loaded or saved, or if a new project is created). If you
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choose to turn on the telemetry sharing feature, the Scratch App will transmit this information to Scratch.
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Projects created in the Scratch App are not transmitted to or accessible by Scratch.
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</p>
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<p>
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The anonymous usage information we collect includes data about what parts of the app you use and basic
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information about your network that allows us to roughly estimate what part of the world you are located
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in. We also may collect general information about the device that you are using, such as make, model,
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operating system and screen resolution. We do not collect device identifiers, such as advertising IDs, MAC
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addresses, or IP addresses. We do not associate any of this information with an identified or identifiable
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individual.
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</p>
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<h2>How does the Scratch Team use the information it collects?</h2>
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<h2>How Does Scratch Use My Information?</h2>
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<p>We use this Information for the following purposes:</p>
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<ul>
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<li>
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We may use anonymous usage information in research studies intended to improve our understanding of how
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people learn with Scratch. The results of this research are shared with educators and researchers
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through conferences, journals, and other publications.
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<b>Analytics and Improving the Scratch App</b> - We use the Information to analyze use of the Scratch
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App and to enhance your learning experience on the Scratch App.
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</li>
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<li>
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We analyze the information to understand and improve Scratch, such as determining which elements are
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most used and how long users spend in the app.
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<b>Academic and Scientific Research</b> - We de-identify and aggregate Information for statistical
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analysis in the context of scientific and academic research. For example, to help us understand how
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people learn through the Scratch App and how we can enhance learning tools for young people. The
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results of such research are shared with educators and researchers through conferences, journals, and
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other academic or scientific publications. You can find out more on our <a
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href="https://scratch.mit.edu/research"
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target="_blank"
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rel="noopener noreferrer"
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>Research page</a>.
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</li>
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<li>
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We will never share anonymous usage data with any other person, company, or organization, except:
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<ul>
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<li>
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As required to comply with our obligations under the law
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</li>
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<li>
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For technical reasons, if we are required to transfer the data on our servers to another
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location or organization
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</li>
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</ul>
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<b>Legal</b> - We may use your Information to enforce our <a
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href="https://scratch.mit.edu/terms_of_use"
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target="_blank"
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rel="noopener noreferrer"
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>Terms of Use</a>, to defend our legal rights, and to comply with our legal obligations and internal
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policies. We may do this by analyzing your use of the Scratch App.
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</li>
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</ul>
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<h2>What Are The Legal Grounds For Processing Your Information?</h2>
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<p>
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If you are located in the European Economic Area, the United Kingdom or Switzerland, we only process your
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Information based on a valid legal ground. A “legal ground” is a reason that justifies our use
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of your Information. In this case, we or a third party have a legitimate interest in using your Information
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(if you choose to allow the Scratch App to send the Scratch team your Information) to create, analyze and
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share your aggregated or de-identified Information for research purposes, to analyze and enhance your
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learning experience on the Scratch App and otherwise ensure and improve the safety, security, and
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performance of the Scratch App. We only rely on our or a third party’s legitimate interests to process your
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Information when these interests are not overridden by your rights and interests.
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</p>
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<h2>How Does Scratch Share My Information?</h2>
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<p>
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We disclose information that we collect through the Scratch App to third parties in the following
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circumstances:
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</p>
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<ul>
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<li>
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<b>Service Providers</b> - To third parties who provide services such as website hosting, data
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analysis, Information technology and related infrastructure provisions, customer service, email
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delivery, and other services.
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</li>
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<li>
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<b>Academic and Scientific Research</b> - To research institutions, such as the Massachusetts Institute
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of Technology (MIT), to learn about how our users learn through the Scratch App and develop new
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learning tools. The results of this research or the statistical analysis may be shared through
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conferences, journals, and other publications.
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</li>
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<li>
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<b>Merger</b> - To a potential or actual acquirer, successor, or assignee as part of any
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reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any
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portion of our organization or assets. You will have the opportunity to opt out of any such transfer if
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the new entity's planned processing of your Information differs materially from that set forth in
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this Privacy Policy.
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</li>
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<li>
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<b>Legal</b> - If required to do so by law or in the good faith belief that such action is appropriate:
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(a) under applicable law, including laws outside your country of residence; (b) to comply with legal
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process; (c) to respond to requests from public and government authorities, such as school, school
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districts, and law enforcement, including public and government authorities outside your country of
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residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of
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our affiliates; (f) to protect our rights, privacy, safety, or property, and/or that of our affiliates,
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you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may
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sustain.
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</li>
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</ul>
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<h2>Children and Student Privacy</h2>
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<p>
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The Scratch Foundation is a 501(c)(3) nonprofit organization. As such, the Children's Online Privacy
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Protection Act (COPPA) does not apply to Scratch. Nevertheless, Scratch takes children's privacy
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seriously. Scratch collects only minimal information from its users, and only uses and discloses
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information to provide the services and for limited other purposes, such as research, as described in this
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Privacy Policy.
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</p>
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<p>
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Scratch does not collect information from a student's education record, as defined by the Family
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Educational Rights and Privacy Act (FERPA). Scratch does not disclose information of students to any third
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parties except as described in this Privacy Policy.
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</p>
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<h2>Your Data Protection Rights (EEA)</h2>
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<p>
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If you are located in the European Economic Area, the United Kingdom or Switzerland, you have certain
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rights in relation to your Information:
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</p>
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<ul>
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<li>
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<b>Access, Correction and Data Portability</b> - You may ask for an overview of the Information we
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process about you and to receive a copy of your Information. You also have the right to request to
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correct incomplete, inaccurate or outdated Information. To the extent required by applicable law, you
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may request us to provide your Information to another company.
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</li>
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<li>
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<b>Objection</b> – You may object to (this means “ask us to stop”) any use of your
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Information that is not (i) processed to comply with a legal obligation, (ii) necessary to do what is
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provided in a contract between Scratch and you, or (iii) if we have a compelling reason to do so (such
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as, to ensure safety and security in our online community). If you do object, we will work with you to
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find a reasonable solution.
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</li>
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<li>
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<b>Deletion</b> - You may also request the deletion of your Information, as permitted under applicable
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law. This applies, for instance, where your Information is outdated or the processing is not necessary
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or is unlawful; where you withdraw your consent to our processing based on such consent; or where you
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have objected to our processing. In some situations, we may need to retain your Information due to
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legal obligations or for litigation purposes. If you want to have all of your Information removed from
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our servers, please contact <a
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href="mailto:help@scratch.mit.edu"
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target="_blank"
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rel="noopener noreferrer"
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>help@scratch.mit.edu</a> for assistance.
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</li>
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<li>
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<b>Restriction Of Processing</b> - You may request that we restrict processing of your Information
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while we are processing a request relating to (i) the accuracy of your Information, (ii) the lawfulness
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of the processing of your Information, or (iii) our legitimate interests to process this Information.
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You may also request that we restrict processing of your Information if you wish to use the Information
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for litigation purposes.
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</li>
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<li>
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<b>Withdrawal Of Consent</b> – Where we rely on consent for the processing of your Information, you
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have the right to withdraw it at any time and free of charge. When you do so, this will not affect the
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lawfulness of the processing before your consent withdrawal.
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</li>
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</ul>
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<p>
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In addition to the above-mentioned rights, you also have the right to lodge a complaint with a competent
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supervisory authority subject to applicable law. However, there are exceptions and limitations to each of
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these rights. We may, for example, refuse to act on a request if the request is manifestly unfounded or
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excessive, or if the request is likely to adversely affect the rights and freedoms of others, prejudice the
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execution or enforcement of the law, interfere with pending or future litigation, or infringe applicable
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law. To submit a request to exercise your rights, please contact <a
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href="mailto:help@scratch.mit.edu"
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target="_blank"
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rel="noopener noreferrer"
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>help@scratch.mit.edu</a> for assistance.
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</p>
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<h2>Data Retention</h2>
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<p>
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We take measures to delete your Information or keep it in a form that does not allow you to be identified
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when this Information is no longer necessary for the purposes for which we process it, unless we are
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required by law to keep this Information for a longer period. When determining the retention period, we
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take into account various criteria, such as the type of services requested by or provided to you, the
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nature and length of our relationship with you, possible re-enrollment with our services, the impact on the
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services we provide to you if we delete some Information from or about you, mandatory retention periods
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provided by law and the statute of limitations.
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</p>
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<h2>How Does Scratch Protect My Information?</h2>
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<p>
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Scratch has in place administrative, physical, and technical procedures that are intended to protect the
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Information we collect on the Scratch App against accidental or unlawful destruction, accidental loss,
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unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of
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processing of the Information. However, as effective as these measures are, no security system is
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impenetrable. We cannot completely guarantee the security of our databases, nor can we guarantee that the
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Information you supply will not be intercepted while being transmitted to us over the Internet.
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</p>
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<h2>International Data Transfer</h2>
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<p>
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We may transfer your Information to countries other than the country where you are located, including to
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the U.S. (where our Scratch servers are located) or any other country in which we or our service providers
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maintain facilities. If you are located in the European Economic Area, the United Kingdom or Switzerland,
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or other regions with laws governing data collection and use that may differ from U.S. law, please note
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that we may transfer your Information to a country and jurisdiction that does not have the same data
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protection laws as your jurisdiction. We apply appropriate safeguards to the Information processed and
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transferred on our behalf. Please contact us for more information on the safeguards used.
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</p>
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<h2>Notifications Of Changes To The Privacy Policy</h2>
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<p>
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We review our Privacy Policy on a periodic basis, and we may modify our policies as appropriate. We will
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notify you of any material changes. We encourage you to review our Privacy Policy on a regular basis. The
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“Last Updated” date at the top of this page indicates when this Privacy Policy was last
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revised. Your continued use of the Scratch App following these changes means that you accept the revised
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Privacy Policy.
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</p>
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<h2>Contact Us</h2>
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<p>
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The Scratch Foundation is the entity responsible for the processing of your Information. If you have any
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questions about this Privacy Policy, or if you would like to exercise your rights to your Information, you
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may contact us at <a
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href="mailto:help@scratch.mit.edu"
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target="_blank"
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rel="noopener noreferrer"
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>help@scratch.mit.edu</a> or via mail at:
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</p>
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<div className="vcard">
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<div className="org">Scratch Foundation</div>
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<div className="fn">ATTN: Privacy Policy</div>
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<div className="adr">
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<div className="street-address">201 South Street</div>
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<span className="locality">Boston</span>, <span className="region">MA</span> <span
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className="postal-code"
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>02111</span>
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</div>
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</div>
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</div>
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);
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