Privacy Policy



Last updated April 04, 2018

Picta Dicta LLC (“we” or “us” or “our”) respects the privacy of our users (“user” or “you”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website including any other media form, media channel, mobile website, or mobile application related or connected thereto (collectively, the “Site”). Please read this Privacy Policy carefully. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS THE SITE.  

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Revised” date of this Privacy Policy. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Site, and you waive the right to receive specific notice of each such change or modification. You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Site after the date such revised Privacy Policy is posted.  

1. Users of the Picta Dicta web application

There is an important distinction in the kinds of our users, especially in regard to the collection and use of personally identifiable information:

· Account holders are 18 years or older: parents, teachers, and/or adults that wish to use our service for themselves. Only account holders create accounts, register and manage courses, and enter personally identifiable information of any sort.

· Learners are usually the children of account holders or the students of account holders; additionally, account holders may enroll themselves as learners. Learners receive separate login credentials from the associated account holder and only have access to the courses assigned to them by the associated account holder.

2. What information does Picta Dicta collect?

When you use Picta Dicta, we collect information relating to you and your interaction with our services. These are listed below. The sections afterward describe what we do with this information.

Information we collect directly from you

· Account holder information. In order to use the Picta Dicta app, an adult (18 years or older) must first create a Picta Dicta account. During registration, we collect this account holder’s first name, last name, email address, username, and password.

· Learner information. Once an account has been created, an account holder creates learner profiles (either for themselves or others for whom they are responsible). During the creation of learner profiles, we collect from the account holder the first name, last name, age, username, and password of each learner.

· Course Settings. When an account holder first enrolls a learner in a course offered through Picta Dicta (and when a learner’s profile is edited afterward), we collect the account holder’s choice of a difficulty setting (called a campaign) for the learner.

Information we collect indirectly from you

· Game Data. A learner proceeds through a campaign by playing games. During each game, we collect data about the game, every problem encountered in the game, and the learner’s interaction with that problem. This data includes but is not limited to timestamps, whether a problem is answered correctly or not, and answers themselves if given incorrectly.

3. How do we use the information we collect?

We use the information we collect from you in order to provide you with a customized experience with our services. Here are some specific ways in which we do this:

· To create and manage your account. Account holders create accounts, create learner profiles for their accounts, add product licenses to their accounts, enroll learners in courses, select settings for the learners and courses, etc.

· To provide account holders with the ability to analyze associated learners’ performance in their courses. Account holders have the ability to view each learner’s game history, how much time they have spent using the app, their performance, etc. They may, in some circumstances, also be able to view analysis of a learner’s performance: for example, a chart showing a learner’s performance in different categories.

· To provide a customized learning experience for learners. Learners proceed through campaigns based on what games they have completed. Also, they have access to some games that select material based on their history: for example, games that select the most missed material or the least recently seen material.

· To provide customer support to account holders. If there is a temporary service outage or scheduled maintenance, we notify account holders by email. If there is some problem with an account, we notify the account holder by email. If an account holder makes a request for additional information not already provided in the dashboard, we send that information by email. 

· To manage our services. We may use your information to analyze and measure user behavior and trends, to understand how people use our services, and to monitor, troubleshoot and improve our services, including to help us evaluate or devise new features. We may use your information for internal purposes designed to keep our services secure and operational, such as for troubleshooting and testing purposes, and for service improvement, marketing, research and development purposes.

· To enforce our Terms of Use. We reserve the right to use any of the information we collect to determine whether or not a user of any sort is violating our Terms of Use.

4. Security, Confidentiality, etc.

· We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information. 

5. Policy for Children

· Collection of Personal Information. We do not knowingly solicit or collect personal information from minors. Account holders must be 18 years or older, and we only collect personal information from account holders. An account holder of legal age may create a learner profile on behalf of a minor of any age with the permission of the minor’s parent or guardian; however, once a learner logs in to use our services, we do not solicit or collect personal information from the learner.

· Contact with Learners. We do not knowingly communicate to minors. We do not collect email addresses or any other information that would allow us to contact learners (who may be minors) directly—we only contact account holders. 

· Marketing and Advertising. We do not knowingly market to or allow third parties to market to minors through our site. We do not collect any contact information for Learners, and once a Learner (who may be a minor) has logged in, there are no advertisements from us or any third parties.

6. Sharing and Disclosure of your Information

· Service Providers. We engage certain trusted third parties to perform functions and provide services to us: such as hosting, maintenance, mail delivery, database storage, management, data analysis, etc. We share your personally identifiable information with these third parties, but only to the extent necessary to perform these functions and provide such services, and only pursuant to binding contractual obligations requiring such third parties to maintain the privacy and security of your data.

· Compliance with Laws and Law Enforcement. We reserve the right to communicate your personal information to government, law enforcement officials, or private parties that make a legally-compliant request for the disclosure of personal information.

· Research. We may share data with third parties about learner performance in the aggregate (as a lump of data) without connection to personally identifiable information.

7. Privacy Policy Updates and Notification

· Changes to our privacy policy. We may update and modify this privacy policy at any time; however, if we do, we will notify you by publishing the changes on this website. If we determine that the changes are significant, we will provide you with additional notice via email. If, after being informed of the changes in privacy policy, you continue to use our services beyond the advance-notice period, you will be considered as having expressly consented to the changes in our privacy policy. If you do not consent to the terms of this privacy policy or any updated privacy policy, you may close your account.

8. Managing Personal Information

· Updating a Learner’s Personal Information. An account holder may make changes to a learner’s personal information at any time. To edit a learner’s personal information, go to the Learners section of the account dashboard. Find the name of the learner and click the edit icon beside that learner’s name. Make any changes in the form and select save.

· Updating an Account Holder’s Personal Information. At any time, account holders may edit their own personal information. To edit an account holder’s personal information, go to the accounts dashboard and click on the account username in the top bar. Make any changes in the form and select save. 

· Deleting a Learner’s Personal Information. At any time, account holders may delete a learner’s profile.  To delete a learner profile, go to the Learner section of the Accounts Dashboard and select the delete icon by a learner’s name. Once you have confirmed that you wish to delete this learner’s profile, we delete all the personal identifiable information associated with this profile. Although the data history for this profile remains in our records, it is no longer associated with any particular person. The account holder will receive a code by email that may be used to restore this data history, should the account holder ever decide to recreate this learner’s profile.

· Deleting an Account Holder’s Personal Information. An account holder may request to have their account closed and deleted by emailing When an account is closed and deleted, all personally identifiable information for the account holder and any active learners will be deleted as well.