Privacy Policy for Hexis’ Software Platform

Introduction

HEXIS Ventures Inc. (“Hexis”) is an educational software platform (ESW) designed to help students and teachers collaborate and learn. Our platform values the privacy and security of our users and is committed to protecting their personal information.

Hexis is committed to protecting the privacy of its users and wishes to maintain a safe and secure environment for all users of the ESW. Please read the following Privacy Policy to understand how your personal information is treated. From time to time, Hexis may offer new services and/or products that may require Hexis to update this Privacy Policy. Please check back periodically. If you have questions or concerns regarding this policy, contact Hexis’ Privacy Administrator at info@hexisventures.com.

Information Collected by Hexis

Automatically Collected Data / Log Data

Like most companies offering online services, the ESW gathers certain information automatically from your computer or mobile device and stores it. This information may include Internet protocol (IP) address, operating system, device type, browser type, content viewed, Internet services provider (ISP), approximate location, referring/exit pages, date/time stamps, and clickstream data. Hexis uses this information, which does not identify individual users, to analyze trends, administer the ESW, gather demographic information about its user base, and improve its level of service.

Information You Provide

Hexis does not collect any personal information about you unless you voluntarily provide it. To use certain features of the ESW, a user may need to submit certain information. Some information may be necessary to provide the educational experience, for example:

• Personal information such as name, email address, profile picture, and age
• Demographic information such as gender and location
• Course-related information such as enrollment and grades
• Communication preferences and settings

The provision of at least some of this personal information is mandatory to create an account and use certain features of the ESW. Hexis does not collect any financial information from users of its ESW.

Cookies and Google Analytics

The ESW does not rely on the use of cookies and does not use Google Analytics.

Use of Personally Identifiable Information

Personally identifiable information collected is used primarily for the purpose for which it is collected (e.g., creating a user account). We use this information to provide our services, improve service quality, personalize the user experience, and communicate with users. We may also use this information for research purposes and to comply with legal requirements. Hexis may contact users regarding inappropriate use of the ESW.

Disclosure of Personally Identifiable Information

Hexis does not sell, rent, or lease your personal information to third parties.

Hexis may disclose your personal information to organizations that perform services for or on behalf of Hexis—such as customer service, research, marketing, data processing, and usage measurement. We share only the information they need to work on our behalf. Some service providers may be located in other countries. Your personal information will be provided to these organizations only if they agree to use such information solely to provide services to Hexis, under Hexis’ instructions, and in a manner consistent with this Privacy Policy.

Hexis will share your personal information with the Academic Institution or company linked to your use of our ESW. Where permitted, we may also share information with relevant parties associated with the Academic Institution (e.g., educators, fellow students, or parents/guardians).

Example: If your Academic Institution uses our ESW as a learning management platform and has given you access to it, or if you are taking a course via the ESW, we will share the personal information you provided upon account and course registration with the educator and/or Academic Institution.

Information Security

The ESW has commercially reasonable security measures in place to prevent the loss, misuse, and alteration of the information that Hexis obtains from you, but Hexis makes no assurances about its ability to prevent any such loss, misuse, or alteration. Please review Hexis’ Terms of Service regarding liability.

Updating Information

You have the right to correct and update the personal information collected about you. You can make changes at any time by logging into your account with your email and password, or by contacting info@hexisventures.com.

Notifications of Changes to this Privacy Policy

Hexis reserves the right to make changes to this Privacy Policy. In the event of a material change in our information collection and handling practices, Hexis will inform users who have provided an email address. Any changes will apply prospectively only.

Links

The ESW may contain links to other websites. Hexis is not responsible for the privacy practices or the content of such websites. We encourage users to read the privacy policies of each website that collects personally identifiable information. This Privacy Policy applies solely to information collected by Hexis.

Notice Regarding Children

The ESW is a general audience website and does not direct any of its content specifically at children under 13 years of age. If Hexis learns or has reason to suspect that a user is under age 13, Hexis will promptly delete any personal information for that user.

Notice to California Residents

Hexis does not disclose your information to third parties for marketing purposes. California residents may request information identifying all third-party companies to which we may have disclosed, within the past year, personal information pertaining to them and their families for those companies’ direct marketing purposes, and a description of the categories of personal information disclosed. To obtain such information, email info@hexisventures.com.

California Do Not Track (DNT) Disclosure

Hexis does not track customers over time and across third-party websites to provide targeted advertising and therefore does not respond to DNT signals. Some third parties may track your browsing activities independently. Your browser may allow you to enable DNT for third-party sites.

International Users

Hexis is a U.S. company and the ESW is hosted in the United States. By using the ESW from outside the U.S., you acknowledge that your personal information is transferred to and processed in the United States (and potentially other countries) where privacy laws may be less stringent than in your country. If applicable law grants you access rights, you may access, correct, or update your information through your account or by emailing info@hexisventures.com.

Required Disclosures

Hexis may disclose personal information when required by law or in the good-faith belief that such action is necessary to comply with legal process or applicable law.

How to Contact Hexis About Privacy Concerns

If you have any questions or comments regarding this Privacy Policy, contact us at info@hexisventures.com.

For Users in the EU and Switzerland

Hexis as Controller

When you provide Hexis with your information through our Website, Hexis serves as a data controller and determines how personal information will be utilized in accordance with this Privacy Policy.

Legal Basis for Processing Your Personal Data

Hexis processes personal information to perform contractual obligations (provide the Services/ESW), based on legitimate interests (operate, develop, improve, prevent fraud, comply with requests), and—where obtained—based on consent.

Data Subject Rights — Access and Control

You can access and review your personal information by logging into the ESW and visiting your account.

Right to Rectification

You may correct inaccurate or incomplete personal data by updating your account information.

Data Portability

Where processing is automated and based on consent or contract, you may request a copy of your data in a structured, commonly used, machine-readable format and have it transferred to you or a third party.

Right to Restriction of Processing

• While accuracy of contested data is verified
• Where processing is unlawful and you oppose erasure
• Where data is no longer needed but required for legal claims
• While legitimate interests are under objection review

Erasure of Personal Data

You may request deletion by emailing info@hexisventures.com. In some cases we may retain data to comply with legal obligations or protect the rights of others.

Retention

Hexis retains personal data as long as necessary to provide the Services and to comply with legal obligations, resolve disputes, and enforce agreements, after which it is deleted.

How to Exercise Your Rights

Email info@hexisventures.com. Many rights can also be exercised through your account.

Right to Complain to Supervisory Authority

If you believe your data is being processed incorrectly or unlawfully, you may contact Hexis or file a complaint with an EU Supervisory Authority.

Transfer of Information

Information we collect is stored and processed in the United States. By providing information, you consent to that transfer.

Effective Date: 02/08/2023 · Last updated: 02/08/2023