4.1. Quimbee does not solicit or knowingly collect Personal Information from children under the age of 16 (or a minor in the jurisdiction in which you are accessing our Sites or Services). If you are under the age of 16 (or a minor in the jurisdiction in which you are accessing our Sites or Services), do not use the Services, or make purchases via the Services, use any interactive features of the Services, or post any Personal Information to our Sites or submit any Personal Information via the Services. If Quimbee obtains actual knowledge that it has collected Personal Information from a child under the age of 16, Quimbee will immediately delete that information from its database. If you believe that we might have any information from a child under age 16 in the applicable jurisdiction, please contact us [email protected] If we learn that we have inadvertently collected the Personal Information of a child under 16, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible and cease the use of that information in accordance with applicable law.
5.1. Traffic Data. Like most website and mobile-application operators, Quimbee collects information that web browsers automatically make available, including: (i) IP addresses, (ii) Internet domain names, (iii) types of devices accessing the Service, and (iv) types of Web browsers accessing the Service (collectively “Traffic Data”). Traffic Data is not meant to personally identify you, although it may be possible to identify you using Traffic Data in combination with other data.
5.2.1. First-Party Cookies. Quimbee uses first-party Cookies on the Service for the following purposes: (1) to gather visitor and access information relevant to customizing the Service to your interests and (2) to store your user ID so you do not have to re-enter it each time you use the Service.
5.2.3. Third-Party Cookies and Advertising.
18.104.22.168. Advertising on Third-Party Websites. Quimbee may advertise on other Third-Party Websites to you after you access the Service. We and third-party marketing partners, including without limitation Google, Inc. (“Google”), may use first-party Cookies (such as the Google Analytics Cookie), third-party Cookies (such as the DoubleClick Cookie), and web beacons (such as the Facebook conversion-tracking pixel, see https://www.facebook.com/business/a/online-sales/conversion-tracking), including across multiple devices, to inform, optimize, and serve advertisements to you based on your use of the Service. This practice is commonly known as retargeting or remarketing (see https://en.wikipedia.org/wiki/Behavioral_retargeting).
22.214.171.124. Google Analytics.
126.96.36.199.1. Google Analytics is a web analytics service that helps website and app owners understand how their visitors engage with their properties. It may use a set of Cookies to collect information and report website usage statistics without personally identifying individual visitors to Google. The main Cookie used by Google Analytics is the “__ga” Cookie. Quimbee uses Google Analytics on the Quimbee website.
5.2.4. Opting Out of Third-Party Cookies.
188.8.131.52. You may customize your Google Cookies preferences or opt out of using Google Cookies on the Google Ads Settings page at http://www.google.com/settings/ads.
184.108.40.206. You may learn about Facebook Cookies and how to customize your preferences at https://www.facebook.com/about/ads.
220.127.116.11. You may opt out of using other third parties’ Cookies by visiting the Network Advertising Initiative opt-out page at http://www.networkadvertising.org/managing/opt_out.asp. You can also learn more about how to delete or control Cookies at http://www.aboutcookies.org/.
5.3. Third-Party Analytics Services.
Quimbee selects Third-Party Analytics Services to help provide the Service to you; for example, Google Analytics. Quimbee only shares information with the Third Party that is required for the service they are offering and contractually bind these providers to keep any information Quimbee shares with them as confidential and to be used only for particular purposes.
5.4. Analytics Policy and Device Ad ID Collection.
5.4.1. Advertising IDs or “Device Ad ID”s are files that are placed on your mobile application by your device manufacturer. More information is available at https://developer.android.com/google/play-services/id.html. The purpose of a Device Ad ID is to identify the User as a unique user of the Service without collecting Personal Information.
5.4.2. Quimbee collects Device Ad IDs.
5.4.3. If you do not wish for Quimbee to access your Device Ad ID, you must inform Quimbee of your opt-out immediately, using the “Contact Us” form available through your account, and then permanently cease all use of Quimbee. If you opt out in this fashion, you assume all responsibility for any resulting loss of functionality.
5.5. Personal Information. To use certain features of the Service, you might be asked to provide Quimbee certain information identifiable to you (“Personal Information”). You may provide to Quimbee Personal Information which includes, but is not limited to, the following categories (1) “Contact Data” (such as your name, phone number, fax number, mailing address, and email address); (2) “Financial Data” (such as your credit/debit card number, expiration date, and billing address); (3) “Demographic Data” (such as your law school graduation date, law school attended, and your billing ZIP code); (4) “Third-Party Social Media Account Data” (such as your account information for third-party social media accounts when you access the Service in connection to those accounts); (5) “Work History Data” (such as your resume, including education and experience); and (6) “Profile Data” (such as your profile picture for display next to publicly posted Questions and Answers). Quimbee may supplement the Personal Information you provide with additional Personal Information gathered from public sources or from third parties (e.g., consumer reporting agencies) who may lawfully provide that information to Quimbee. You are under no obligation to provide Personal Information, but your refusal to do so may prevent you from using certain features of the Service.
5.5.1. Entity Users and Group Managers Have No Right to Personal Users’ Personal Information. Entity Users and Group Managers generally may not access the Personal Information of Personal Users with access under an Institutional Agreement or Group subscription plan. Entity Users and Group Manager may see the email address and (if applicable) invitation status of any Personal User with access under the Individual Subscription or Group subscription plan. In addition, Entity Users and Group Managers may see aggregate usage statistics.
5.6. Information You Make Public. The Service may contain features (e.g., instant messages, electronic messaging, etc.) that allow you to upload, post, transmit, display, perform, or distribute content, or other information, including your Personal Information. Any information that you choose to disclose through such features becomes public information over which Quimbee is unable to exercise control. You should exercise caution when deciding to disclose your Personal Information through these features, and you agree to assume all responsibility for doing so. Information you make public, including your profile picture, profile information, and posting-activity information, may be accessed and viewed by other Quimbee Users or site visitors. You acknowledge and agree that you are responsible for the content of any information you make public, including by posting publicly or uploading pictures, and any harm you cause to others through making that information public or by using any Quimbee feature.
5.6.1. Entity Users and Group Managers Have No Claim Over Information Personal Users Make Public. Entity Users and Group Managers may not prevent Personal Users with access under an Institutional Agreement or Group subscription plan from utilizing features that allow them to upload, post, transmit, display, perform, or distribute content, or other information, including their Personal Information. Any information that a Personal User chooses to disclose through such features becomes public information over which Quimbee is unable to exercise control. Personal Users should exercise caution when deciding to disclose their Personal Information through these features, and Personal Users agree to assume all responsibility for doing so. Information Personal Users make public may be accessed and viewed by other Quimbee Users or site visitors. Personal Users acknowledge and agree that they are responsible for the content of any information they make public, including by posting publicly or uploading pictures, and any harm Personal Users cause to others through making that information public or by using any Quimbee feature. Entity Users and Group Managers acknowledge and agree that they are responsible for the content of any information they make public on their personal accounts but have no right of ownership or control with respect to the content any Personal User chooses to make public.
5.7. Mobile Device Information. Quimbee may collect: (i) information about the type, make, and model of your mobile device, the operating system you use on the device, browser type and specifications, the network service or wireless communication provider who connects your device to a telecommunications system or systems, your internet protocol address, and other unique identifiers assigned by third parties to your mobile device, and (ii) information about your activity on the device, including your use of other mobile applications on the same device, click data and click patterns in relation to promotional advertising on your device, Cookies (defined above), tracking tags, pixel tags, web beacons, and visitor history.
5.8. Location Information. If you grant us access to your location, Quimbee may collect information about your location when you use our Sites and Services. Your location can be determined by: GPS, IP address, and information about things near your device, such as Wi-Fi access points and cell towers. When you use our Services via a wireless device, we may solicit your permission to collect your location data. Some features within our application may only function upon confirmation of your location, and therefore such features will not be available if you choose not to provide your location data to us. The specificity of the location data collected may depend on a number of factors, including the device you are using (e.g. laptop, smartphone or tablet) and how you are connected to the Internet (e.g., via cable broadband connection, WiFi). If you enable location services for our mobile application, we may collect location data periodically as you use or leave open our mobile application. We may associate such location data with Personal Information you provide to us. Depending on the platform you use to access our mobile application (e.g., Apple’s iOS, Google’s Android), you may be able to control whether location data is collected from within “Settings” or other controls on your wireless device or the mobile application.
During the last twelve (12) months, we have collected the following categories of Personal Information from users:
A. Identifiers: First and last name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): A name, address, telephone number, education (law school), employment, employment history and disciplinary action (for our employees), professional memberships, employee reference checks, credit card number, debit card number, or any other financial information.
C. Protected classification characteristics under California or federal law: Age, nationality, racial or ethnic origin, marital status, sex (including gender, gender identity, gender expression), sexual orientation.
D. Commercial information: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Internet or other similar network activity: Browsing history, search history, information on a consumer's interaction with a website, application logs, device data and registration, social media account information or advertisement.
I. Professional or employment-related information: Current or past job history or performance evaluations; disciplinary action, professional memberships, employee reference checks, and trade union membership
J. Inferences drawn from other personal information: Profile reflecting a person's preferences, behavior, and attitudes.
We obtain the categories of Personal Information listed above from the following categories of sources:
Directly from our Users or their agents.
Indirectly from our Users or their agents. For example, through information we collect from our clients in the course of providing Services to them.
Directly and indirectly from activity on our website, www.quimbee.com. For example, from website usage details that are collected automatically. In addition, like many companies, we use “cookies” which are small text files a website can use to recognize repeat Users, facilitate the User’s ongoing access to and use of the site and to track usage behavior of, for example, the webpages you visit.
From social media websites, such as Facebook, Twitter, LinkedIn, YouTube, Instagram, and Pinterest.
From third parties that assist us in providing certain transactions and services, even though it appears that you may not have left our Site.
7.1. Traffic Data and Information Gathered Using Cookies. Quimbee analyzes Traffic Data and information gathered using Cookies to help Quimbee better understand who is using the Service and how they are using it. By identifying patterns and trends in usage, Quimbee is able to better design the Service to improve your experience and to serve you more relevant and interesting content. From time to time, Quimbee may release Traffic Data and information gathered using Cookies in the aggregate, such as by publishing a report on trends in the usage of the Service. Quimbee does not attempt to link information gathered using Cookies to Personal Information.
7.2. Personal Information.
7.2.2. Disclosure Practices. Except under the following categories of circumstances, Quimbee will keep your Personal Information private and will not share it with third parties. In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for one or more business purposes:
California Customer Records Personal Information categories;
Protected classification characteristics under California or federal law;
Internet or other network activity information;
Professional or employment-related information;
Inferences drawn from other personal information.
18.104.22.168. Disclosure to Third-Party Partners in Connection with an Exclusive Discount or Offer. Quimbee offers exclusive discounts and benefits to certain Third-Party Partners and their members or customers. You might claim one of those discounts and benefits, in which case Quimbee may use your Personal Information to help our Third-Party Partners better understand the demographics of our target audiences, as well as to support both the marketing of Quimbee’s Services and our Third-Party Partner’s products and services.
22.214.171.124. Disclosure in Connection with Service. Quimbee discloses Personal Information to those who help it provide Services, including without limitation those who perform technical, administrative, and data-processing tasks such as hosting, billing, fulfillment, data storage, and security.
126.96.36.199. Disclosure in Connection with Product Development and Improving Educational Outcomes. Quimbee may disclose Personal Information, including information related to your Quimbee website usage and course completion, with educational institutions, professors, law school administrators, and product-development partners. Please note that if your employer has purchased Quimbee’s products or services for you, we may also share information about your website usage and course completion with them.
188.8.131.52.1. Disclosure in Connection with Quimbee Bar Review. By utilizing Quimbee Bar Review, you expressly authorize Quimbee to share Personal Information, including information about your website usage, essay and performance-test submissions, and course completion, with your law school (including professors and other faculty, bar success personnel, academic support professionals, and other administrators) for the purposes of (1) facilitating your school to provide individualized support to you, (2) allowing your school to maintain better statistics related to its graduates' bar exam preparation, (3) improving Quimbee's products and services, and (4) other related objectives.
184.108.40.206. By Law or to Protect Rights. Quimbee discloses Personal Information when required to do so by law, in response to a subpoena or court order, or when Quimbee believes in its sole discretion that disclosure is reasonably necessary to protect the property or rights of Quimbee, third parties, or the public.
220.127.116.11. Unpaid Accounts. If you fail to pay any balance owed in consideration of Services, Quimbee may, as permitted by law, report your Personal Information, including without limitation your unpaid balance, to consumer credit reporting services, collection agencies, and others.
18.104.22.168. Sale of Personal Information. We do not sell Personal Information.
Without limitation, by registering for the Service and/or by providing your name, email, postal or residential address, and/or phone number through the Service, you expressly consent to receive electronic and other communications from Quimbee, over the short term and periodically, including email communications, regarding the Service, new product offers, promotions, and other matters. You may opt out of receiving electronic communications at any time by (a) following the unsubscribe instructions contained in each communication or (b) sending an email to [email protected]
Quimbee takes security seriously. Quimbee maintains administrative, technical and physical safeguards designed to protect the User's Personal Information and other information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. For example, we and/or our service providers use commercially reasonable security measures such as encryption, firewalls, and Secure Socket Layer software (SSL) or hypertext transfer protocol secure (HTTPS) to protect Personal Information.
Although we take reasonable steps designed to protect your Personal Data, please be advised that no security system or means of transmitting data over the Internet can be guaranteed to be entirely secure (including without limitation with respect to computer viruses, malicious software and hacker attacks). We cannot and do not guarantee or warrant the security of your Personal Information or any information you disclose or transmit to us. We are not responsible for the acts of those who gain unauthorized access, and we make no warranty, express, implied or otherwise, that we will prevent such access, and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law. Where required under law, we will notify you of any such loss, misuse or alteration of Personal Information that may affect you so that you can take the appropriate actions.
You must promptly notify us if your credit, bank, other financial institution information, username, or password is lost, stolen, or used without permission. In such an event, we will remove the compromised information and update our records accordingly.
Quimbee wants your Personal Information to be complete and accurate. As stated in the Terms of Service, by using the Service, you represent and warrant that all information you provide in connection with your use of the Service is current, complete, and accurate, and that you will update that information as needed to maintain its completeness and accuracy. Subject to applicable law, you may obtain a copy of personal information we maintain about you or you may update or correct inaccuracies in that information by accessing your Settings page. To confirm the completeness and accuracy of, or make changes to, your Personal Information, visit your Settings page. Through your Settings page, you may review and update your Personal Information that we have already collected. Please note that if you post, answer, or reply using Quimbee’s Question and Answer feature, you may not subsequently edit your post, but you may remove that post at any time by deleting the post.
12. Privacy Rights Specific to California Residents.
Under the California Consumer Privacy Act, California residents have specific rights regarding their personal information. This section describes Californians’ rights and explains how California residents can exercise those rights.
Below we further outline specific rights which California residents may have under the California Consumer Privacy Act.
Right to Access Your Data. You have the right to request that we disclose certain information to you about our collection, use and disclosure of your Personal Data over the past twelve (12) months. Any disclosures we provide will only cover the 12-month period preceding the receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
Right to Data Portability. You have the right to a “portable” copy of your Personal Data that you have submitted to us. Generally, this means you have a right to request that we move, copy or transmit your Personal Data stored on our servers or information technology environment to another service provider’s servers or information technology environment.
Right to Delete Your Data. You have the right to request that we delete any of your Personal Data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Data from our records, unless an exception applies.
Right to Non-Discrimination for the Exercise of Your Privacy Rights. You have the right not to receive discriminatory treatment by us for exercising your privacy rights conferred by the California Consumer Privacy Act.
o Exercising Your Rights
If you are a California resident who chooses to exercise your rights, you can submit a request via email to [email protected]
You may also designate an agent to exercise your privacy rights on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification.
o Our Response to Your Request
Upon receiving your request, we will confirm receipt of your request by either sending you an email, confirming receipt via our online portal, or sending a message to your online account. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. In some instances, such as a request to delete personal information, we may first separately confirm that you would like for us to in fact delete your personal information before acting on your request.
We will respond to your request within forty-five (45) days. If we require more time, 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 that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
In some cases, our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, listed below, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
Complete the transaction for which we collected the Personal Data, 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 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; or
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We currently provide the following opt-out opportunities:
- At any time, you can follow a link provided in offers, newsletters, or other email messages (except for e-commerce confirmation or service notice emails) received from us to unsubscribe from the service.
California Civil Code Section § 1798.83 permits Users of our Site 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 write to us at the address listed in the How to Contact Us section below. We do not disclose personal information to third parties for the third parties’ direct marketing purposes.
Quimbee does not respond to “Do Not Track” signals sent by browsers.