Turuly, Inc., doing business as EducatorResourceCenter.org, is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the Personal Information (as defined below) we collect from users of our Site at www.EducatorResourceCenter.org.com and Services (as defined in the Terms of Service). It also describes the choices available to you regarding the use of your Personal Information and how you can access and update this information. Capitalized terms not defined in this Privacy Policy have the meanings given in our Terms of Service located at http://EducatorResourceCenter.org.com/pages/tos.

1. User Consent.

By submitting Personal Information through our Site or Services, you expressly consent to the collection, use and disclosure of your Personal Information in accordance with this Privacy Policy.

2. Visitors under the age of 13.

Our Service is not offered to persons under the age of 13. Thus, we do not intentionally gather Personal Information from visitors who are under the age of 13.

3. Types of Data We Collect

“Personal Information” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data that is not associated with or linked to your Personal Information; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Information and Anonymous Data, as described below.

a. Information You Provide to Us.

We may collect Personal Information from you, such as your name, e-mail and mailing addresses, phone number, and password when you create an account with us (“Account”).

If you are a Provider (a writer), we may require that you provide your tax information (e.g., social security number).

When you make a purchase, we (or our third party service provider) will collect all information necessary to complete the transaction, including your name, credit card information, debit card information, and billing information.

We retain information on your behalf, such as key words, transactional history, messages and any other information that you store using your Account.

If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.

When you post messages on our Site, the information contained in your posting will be stored on our servers and other users will be able to see it.

We may also collect Personal Information at other points in our Site that state that Personal Information is being collected.

YOU SHOULD NOT PROVIDE EducatorResourceCenter.org WITH ANY PERSONALLY IDENTIFIABLE INFORMATION (OR SUBMIT OR POST ANY PERSONALLY IDENTIFIABLE INFORMATION TO THE SITE OR IN RESPONSE TO ANY EMAIL OR OTHER COMMUNICATION) UNLESS YOU WOULD LIKE THAT INFORMATION TO BE USED IN ACCORDANCE WITH THIS POLICY.

b. Information Collected via Technology.

“Cookies” include commonly used pieces of information in the form of small files that are placed on an individual’s computer hard drive to enable the individual to more easily communicate and interact with the Site and Services. We may use cookies on the site or in communications sent through the Services for various purposes, including by way of example:

Saving user preferences;

• Customizing content of the Site for individual users;

• Ensuring that users are not repeatedly sent the same banner ads;

• Recording session information;

• Saving certain information about users of the Site and others who visit the Site; and

• Facilitating and enhancing interaction with the Site.

• EducatorResourceCenter.org does not use cookies to retrieve information from a computer that is unrelated to EducatorResourceCenter.org or the Site or Services.

A cookie does not collect or keep your name or other personally identifying information; however, we may link the information obtained through cookies to other personally identifiable information to give us a better understanding of your preferences, so that we can provide a more meaningful experience to you on our Site and through our Services.

“Web beacons” (also known as “single-pixel” or “clear” GIFs) include electronic images imbedded in the Site or in communications sent through the Services which are invisible to users. Web beacons collect information, such as identifiers, time and date of access, and descriptions of the pages or communications in which the web beacons are imbedded. The Site and communications sent through the Services may include web beacons. We may use the web beacons on the Site and in communications sent through the Services for various purposes, including by way of example to track users who have visited our Site, viewed advertisements on the Site or in communications sent through the Services, or otherwise accessed communications sent through the Services.

We may use an outside advertisement serving company to display advertisements on the Site or in communications sent through the Services. The advertisement serving company may place and collect cookies or web beacons when it displays an advertisement on the Site or through the Services. We do not have access to information that would confirm the use of cookies or web beacons by the advertisement serving company. We may also use a third party provider to analyze data and patterns regarding usage of the Site and the communications sent through Services. This third party provider may use cookies or web beacons to collect such information.

Most browsers will allow you to erase cookies from your computer hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. You may also be able to refuse certain web beacons by adjusting the settings on your browser or email software. Please refer to your browser or email software instructions or help screen to learn more about these functions.

c. Google Analytics.

We currently use Google Analytics as well as Google Analytics for Display Advertising. Google Analytics collects information and reports website trends without identifying individual visitors. Google Analytics uses its own cookie to track visitor interactions. Website owners can view a variety of reports about how visitors interact with their website so they can improve their website and how people find it. Please see the following links for more information about Google Analytics: http://www.google.com/analytics/, http://www.google.com/privacy.html and http://www.google.com/analytics/tos.html. You can also opt-out of Google Analytics for Display Advertising by going to the Google Ads Preferences Manager. We enable Google Analytics’ User-ID feature to get a better understanding of logged-in user engagement data from different devices and multiple sessions. We want to continue to provide the best user experience for our customers and writers. This information enables us to better understand how users interact with our content over an extended period of time. In addition, we have enabled the Google Analytics advertising feature for data collection for display and search remarketing for the purposes of showing remarketing advertisements to visitors of this site.

4. Use of Your Personal Information

a. General Use.

In general, Personal Information you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Information in the following ways:

• to facilitate the creation of and secure your Account;

• identify you as a user in our system;

• improve our Site and Services;

• for our internal research and development;

• customize content to match your preferences;

• prevent suspended users from re-registering;

• provide the Services you request;

• send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;

• send you administrative e-mail notifications, such as security or support and maintenance advisories;

• respond to your inquiries and requests;

• to make telephone calls to you, from time to time, as a part of secondary fraud protection or to solicit your feedback; and

• to send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of EducatorResourceCenter.org.

b. Creation of Anonymous Data.

We may create Anonymous Data records from Personal Information by excluding information (such as your name) that make the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. EducatorResourceCenter.org reserves the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in its sole discretion.

5. Disclosure of Your Personal Information.

We disclose your Personal Information as described below and as described elsewhere in this Privacy Policy.

a. Profile Information.

The profile you create on our Site will be publicly accessible unless otherwise indicated. You may delete your profile by requesting to delete your account by contacting us via phone or by email at support@EducatorResourceCenter.org.com. The information collected during the registration process by EducatorResourceCenter.org may be used by EducatorResourceCenter.org to: contact members, customize content to match your preferences, display member status, and display the date of a member’s last visit

b. Third Party Service Providers.

We may share your Personal Information with third party service providers to: provide you with the Services that we offer you through our Site; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to EducatorResourceCenter.org. These third party service providers are required not to use your Personal Information other than to provide the services requested by EducatorResourceCenter.org.

c. Other Disclosures.

Regardless of any choices you make regarding your Personal Information (as described below), EducatorResourceCenter.org may disclose Personal Information if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on EducatorResourceCenter.org; (c) to protect or defend the rights or property of EducatorResourceCenter.org or users of the Services; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or the Terms of Use.

6. Third Party Websites.

a. Third Party Sites Generally.

When you click on a link to any other website or location, you will leave our Site and go to another site and another entity may collect Personal Information or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of data after you click on links to such outside websites.

b. Social Networking Sites.

If you (i) log on to the Service with your login credentials from a social networking site (such as Facebook, Twitter, or LinkedIn) (“Social Networking Site”) or (ii) associate your Account with your account at a Social Networking Site, we may receive information about you from such Social Networking Site, in accordance with such Social Networking Site’s terms of use and privacy policy (“SNS Terms”). We may add this information to the information we have already collected from you via the Service. If you elect to share your information with these Social Networking Site, we will share information with them in accordance with your election. The SNS Terms will apply to the information we disclose to them.

c. Other Social Media Features.

Our Site includes social media features (“Features”) such as the Facebook Like button, Tweet button and other widgets or interactive mini-programs that run on our Site. These Features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the Feature to function properly. These Features are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the terms of use and privacy policy of the company providing them (e.g., Facebook or Twitter).

7. Your Choices Regarding Your Personal Information

a. Choices.

We offer you choices regarding the collection, use, and sharing of your Personal Information.

When you create an Account on EducatorResourceCenter.org.com, we may periodically send you free newsletters and e-mails that directly promote the use of our Site or Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive, by adjusting your email preferences from within your Account setting page or by contacting us directly (please see contact information below).

Despite your indicated e-mail preferences, we may send you service related communication, including notices of any updates to our Terms of Use or Privacy Policy.

b. Changes to Personal Information.

You may change any of your Personal Information in your Account by editing your profile within your Account or contacting us via the Site. You may request deletion of your Personal Information by contacting us via the site or at support@EducatorResourceCenter.org.com, but please note that we may be required to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives.

We will retain your information for as long as your Account is active or as needed to provide you Services, for fraud prevention and similar purposes and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements..

8. Security of Your Personal Information.

We will use at least industry standard security measures on the Site to protect the loss, misuse and alteration of the information under our control. While there is no such thing as “perfect security” on the Internet, we will take all reasonable steps to insure the safety of your personal information. For example, our policy is that only those individuals who need your personally identifiable information to perform a specific job are granted access to that personally identifiable information. Likewise, all employees and contractors are kept up-to-date on our security and privacy practices. Finally, the servers that we store personally identifiable information on are kept in a secure environment.

9. Blogs.

Our Site offers publicly accessible blogs. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your Personal Information from our blog or community forum, contact us at support@EducatorResourceCenter.org.com. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.

10. Testimonials.

We display personal testimonials of satisfied customers on our Site in addition to other endorsements. If you choose to provide a testimonial on the Site, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at support@EducatorResourceCenter.org.com.

11. Referrals / Tell a Friend.

If you choose to use our referral service to tell a friend about our Site, we will ask you for your friend’s name and email address. We will automatically send your friend a one-time email inviting him or her to visit the Site. EducatorResourceCenter.org stores this information for the sole purpose of sending this one-time email and tracking the success of our referral program. Your friend may contact us to request that we remove this information from our database.

12. Contact Information.

EducatorResourceCenter.org welcomes your comments or questions regarding this Privacy Policy. Please contact us at the following:

support@EducatorResourceCenter.org.com

or

EducatorResourceCenter.org

1245 Pearl St

STE 208

Boulder CO 80302

USA

13. Changes to This Privacy Policy.

This Privacy Policy is subject to occasional revision. Any changes to this Privacy Policy will be effective upon the earlier of thirty (30) calendar days following our dispatch of an e-mail notice to you or thirty (30) calendar days following our posting of notice of the changes on our Site. These changes will be effective immediately for new users of our Service. Changes to this Privacy Policy may affect our use of Personal Information that you provided us prior to our notification to you of the changes. Continued use of our Site or Service, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

14. Verification.

EducatorResourceCenter.org uses a self-assessment approach to ensure its compliance with this Policy. We regularly verify that this Policy is accurate, comprehensive, prominently displayed, completely implemented and in conformity with the Safe Harbor Principles and conduct our self-assessment on an annual basis. We appropriately train our employees and have internal procedures for conducting objective compliance reviews.