(Last Revised on October 5th, 2013)

Transfolios, Inc. (“Company,” “Transfolios”, “we,” or “us”) knows that you care how information about you is used and shared. This Privacy Policy explains what information of yours will be collected by Transfolios when you use Transfolios.com and related services (the “Service”), how the information will be used, and how you can control the collection, correction and/or deletion of information. Capitalized terms that are not defined in this policy are defined in our Terms of Use.

Please revisit this page periodically to stay aware of any changes to this Privacy Policy, which may be revised periodically at our sole discretion, as provided in Section 17 of the Transfolios Terms of Use. If we modify the Privacy Policy, we will make it available through the Service, and indicate the date of the latest revision. In the event that the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change. For example, we may send a message to your e-mail address, if we have one on file, or generate a pop-up or similar notification when you access the Service for the first time after such material changes are made. Our amended Privacy Policy will automatically take effect 30 days after it is made available through the Service, except that (i) we generally only use your personally identifiable information in the manner described in the Privacy Policy in effect when we received that information and (ii) if you do not agree with any changes to the Privacy Policy, you may terminate your account and stop using the Service. Your continued use of the Service after the revised Privacy Policy has become effective indicates that you have read, understood and agreed to the current version of the Privacy Policy.

Information We Collect

  • User-Provided Information: You provide us information about yourself, such as your name and e-mail address, when you register with the Service. The information we collect may vary depending on the features you elect to use. For example, if you are a Teacher who registers for the Course Service, we may collect the name of your school and the subjects you teach. If you correspond with us by email, we may retain the content of your email messages, your email address and our responses. Also, some of the User Content that you submit in connection with the Service may include information about yourself.
  • Information Provided by other Users: We may collect information about you that is provided by other Users. For example, if you are a Student who uses the Course Service, other Users, such as Teachers, may provide information about you, such as your grades or your email address.
  • Log File Information: Log file information is automatically reported by your browser each time you access a web page. When you register with or view our site, our servers automatically record certain information that your web browser sends whenever you visit any website. These server logs may include information such as your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other such information.
  • Clear Gifs Information: When you use the Service, we may employ clear gifs (also known as web beacons) which are used to track the online usage patterns of our users anonymously. No personally identifiable information from your Transfolios account is collected using these clear gifs. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened by recipients. The information is used to enable more accurate reporting, improve the effectiveness of our marketing, and make Transfolios better for our users.
  • Cookies Information: When you visit Transfolios.com, we may send one or more cookies – a small text file containing a string of alphanumeric characters – to your computer that uniquely identifies your browser and lets Transfolios help you log in faster and enhance your navigation through the site. Transfolios uses both session cookies and persistent cookies. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Service may not function properly if the ability to accept cookies is disabled.

How We Use Your Information

We use the personal information you submit to operate, maintain, and provide to you the features and functionality of the Service. Any personal information or content that you voluntarily disclose for posting to the Service (including your User Content) becomes available to the public. If you remove information that you posted to the Service, copies may remain viewable in cached and archived pages of the Service, or if other Users have copied or saved that information.

By providing Transfolios your email address, you consent to our using the email address to send you Service-related notices, including any notices required by law, in lieu of communication by postal mail (“Service messages”). We may also use your email address to send you other messages, including without limitation, changes to features of the Service, or special offers (“offer messages”). If you do not want to receive such email messages, you may opt out or change your preferences in your Settings Panel. Opting out may prevent you from receiving email messages regarding updates, improvements, or offers. You may not opt out of Service-related e-mails. Opting out, however, does not mean that we cannot send you Service messages.

If you choose to use our group invitation service to invite a friend to the Service, we will ask you for that person’s email address and automatically send an email invitation. Transfolios stores this information to send this email, to register your friend if your invitation is accepted, and to track the success of our group invitation service. Your friend may contact us to request that we remove this information from our database at privacy@Transfolios.com. Transfolios may share your information, including, without limitation, your User Content, with other members of groups in which you choose to participate. If you choose to leave the group, the members of said group will no longer have access through the Service to any of your information through said group, but the members of the group may have made copies of information and your User Content and separately have saved them outside of the Service. If you cancel your account with Transfolios, Transfolios will use commercially reasonable efforts to delete your information from the active user databases and cease making your information available through the Service, including your User Content, although we may retain archived copies in accordance with standard backup procedures.

Teachers may submit one or more Student email addresses to the Service and we may use those email addresses to send an invitation message to the Students on the Teacher’s behalf. Transfolios may also send emails on behalf of a Teacher for other notifications related to the Student’s participation in the Course, such as when a grade is posted, or when instructions or comments are provided. In addition, as part of the Course Service, each Teacher and Student can communicate with each other and with other users by posting to the course-page, and we use the email addresses we have on file to process and provide notifications regarding those communications.

Transfolios may use certain information about you and/or your User Content without identifying you as an individual to third parties. We do this for purposes such as analyzing how the Service is used, improving the Service, diagnosing service or technical problems, maintaining security, and personalizing advertisements and promotions.

Transfolios reserves the right, but has no obligation, to monitor the User Content you post on the site. We reserve the right to remove any such information or material for any reason or no reason, including without limitation if in our sole opinion such information or material violates, or may violate, any applicable law or our Terms of Use Agreement, or to protect or defend our rights or property or those of any third party. Transfolios also reserves the right to remove information upon the request of any third party.

We use cookies, clear gifs, and log file information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information; (c) monitor the effectiveness of our service; (d) monitor aggregate metrics such as total number of visitors and traffic; (e) diagnose or fix technology problems reported by our users or engineers that are associated with the IP addresses controlled by a specific web Transfolios or ISP; and (f) help you efficiently access your information after you sign in.

How We Share Your Information

Personally Identifiable Information: Transfolios is not in the business of renting or selling your personally identifiable information, but Transfolios may share your personally identifiable information with third parties in a variety of circumstances in the operation of our business. If we do this, such third parties’ use of your information will generally be bound by an agreement that requires such third party to keep the information confidential consistent with the terms of this Privacy Policy. We may store personal information in locations outside the direct control of Transfolios (for instance, on servers or databases co-located with hosting providers).

At its heart Service is a platform for enabling users to communication and share information in a variety of ways. Any Personally Identifiable Information that you voluntarily choose to include in a message to another user (including communications between Teachers and Students in connection with participation in Courses), or in a publicly accessible area on the Service, such as a public profile page or portfolio, or through posting User Content, will be available to other users who have access to that content. Once you make your Personally Identifiable Information available in this way, it may be collected and used by the recipients without restriction.

As we develop our business, we may buy or sell assets or business offerings. Customer, email, and visitor information is generally one of the transferred business assets in these types of transactions. We may also transfer such information in the course of corporate divestitures, mergers, or dissolution.

From time to time, we may run contests, special offers, or other events or activities (“Events”) on the Service together with a third party partner. If you provide information to such third parties, you give them permission to use it for the purpose of that Event and any other use that you approve. We cannot control third parties’ use of your information. If you do not want your information to be collected by or shared with a third party, you can choose not to participate in these Events.

Transfolios may disclose personal information to any third party if we believe such a disclosure is required by law or subpoena or if we believe that such action is necessary to (a) conform to the law, comply with legal process served on us or our affiliates, or investigate, prevent, or take action regarding suspected or actual illegal activities; (b) to enforce our Terms of Use, take precautions against liability, to investigate and defend ourselves against any third-party claims or allegations, to assist government enforcement agencies, or to protect the security or integrity of our site; and (c) to exercise or protect the rights, property, or personal safety of Transfolios, our Users or others.

Non-Personally Identifiable Information: We may share non-personally identifiable information (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with interested third parties to help them understand the usage patterns for certain Transfolios services and to assist in the provision and development of the Service.

Transfolios may allow third-party ad servers or ad networks to serve advertisements on the Transfolios site. These third-party ad servers or ad networks use technology to send, directly to your browser, the advertisements and links that appear on Transfolios. They automatically receive your IP address when this happens. They may also use other technologies (such as cookies, JavaScript, or web beacons) to measure the effectiveness of their advertisements and to personalize the advertising content. If an advertiser asks Transfolios to show an advertisement to a certain audience and you respond to that advertisement, the advertiser or ad-server may conclude that you fit the description of the audience they are trying to reach. The Transfolios privacy policy does not apply to, and we cannot control the activities of, third-party advertisers, third-party ad servers or ad networks. Please consult the respective privacy policies of such advertisers third-party ad servers or ad networks for more information.

Information That Is Shared With Your Consent: In addition, we may share your information, including, User Content, when we have your consent. This includes sharing information with other services (like Facebook or Twitter) when you’ve chosen to publish your activity on Transfolios to them. For example, you may choose to publish your User Content to Facebook or Twitter. In addition, we may share your information in other instances when you have given us permission to share your information, such as when you share User Content with another User or group.

Information That Is Shared Through the Course Service: Notwithstanding the foregoing, any information you choose to provide through the Course Service should reflect how much you want other Transfolios users to know about you. If you are a Student and you submit information for a Course, such as an assignment or a portfolio, we may send a copy of that assignment or portfolio to your School and/or your Teacher. If you are a Teacher, we may provide a copy of the Course(s) you create or the information you submit, such as grades, to your School. Teachers and/ or Students may be able to designate whether the different pages within the course (e.g., the syllabus, the assignments, and the portfolios) will be “private” or “public.” If all or certain pages within the course are public, these course-pages may be generally readable by any Student or Teacher in the course. Please consider this when designating the privacy settings on your account.

How We Protect Your Information

Transfolios uses certain physical, managerial, and technical safeguards designed to improve the integrity and security of your personal information. We cannot, however, ensure or warrant the security of any information you transmit to Transfolios and you do so at your own risk. Once we receive your transmission of information, Transfolios makes commercially reasonable efforts to ensure the security of our systems. However, please note that no safeguards are immune from failure or circumvention, whether as a result of concerted effort or human error, and Transfolios cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

To protect your privacy and security, we take certain steps (such as requesting a unique password) to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from Transfolios, at all times.

Compromise of Personal Information

In the event that personal information is compromised as a result of a breach of security, Transfolios may notify those persons whose personal information has been compromised, as required by applicable law.

Your Choices About Your Information

You may, of course, decline to submit personally identifiable information through the Service, in which case Transfolios may not be able to provide certain services to you. You may update or correct your account information by logging in to your account. You can review and correct the information about you that Transfolios keeps on file by contacting us directly at info@Transfolios.com.

Children’s Privacy: Protecting the privacy of young children is especially important. For that reason, Transfolios does not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to register as users. If you are under 13, you are not permitted to use this Service – please do not use or access Service at any time or in any manner. If we learn that personally identifiable information has been collected on the Service from persons under 13 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you believe that we might have any information from or about a child under 13, please contact us at info@Transfolios.com and request that we delete that child’s personally identifiable information from our systems.