Effective 2023-09-05

Axim Collaborative (“we” or “us”) cares about your privacy, and we want you to understand our privacy practices. Please read this Privacy Policy to learn how we collect, use, and protect information that specifically identifies you or that, when combined with other information, could be used to identify you (your “Personal Information”).

This Privacy Policy applies to information that we collect through the openedx.org website and its subdomains (the “Site”), and we are the data controller for such information. For clarity: this Privacy Policy does not apply to the Open edX platform software itself or to any specific usage of the software in production by a third party (we do not control or manage the many global websites that use the Open edX platform software).

This Privacy Policy is organized as follows:

• Information we collect about you
• How we use your information
• How we share your information
• Retention, Storage, and Security
• How to manage your Personal Information
• Privacy Policy updates
• Contact information

INFORMATION WE COLLECT ABOUT YOU

Data you provide about yourself.

We collect information that you voluntarily provide to us. For example, we collect information when you contact us or complete online forms or surveys; sign up for accounts to participate in discussion forums, courses, and other interactive experiences offered on the Site; contribute code; or participate in a program that we offer such as the Core Contributor Program or the Marketplace Provider Program.

It is your decision whether to provide your Personal Information. 

• In some cases, the offerings on the Site and our ability to serve you will be limited or unavailable if you choose not to share your Personal Information. For example, to sign up for an account, your name, email, username and password may be required.
• You may also choose to share more Personal Information than is needed. For example, you might add Personal Information to your account profile or to content that you provide, such as writing messages in a forum or providing answers in a training session.

We do not intentionally collect any “sensitive” data under the EU General Data Protection Regulation (GDPR) and other privacy laws without your explicit consent for specified purposes or as otherwise permitted or required by applicable law. Sensitive data include genetic, biometric and health data, data relating to criminal convictions and offenses, data concerning an individual’s sex life or sexual orientation, and Personal Information revealing racial and ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership.

We encourage you to use discretion before voluntarily sharing Personal Information on the Site. (Deletion of your Personal Information will be subject to the process and limits outlined below.)

Data we collect automatically.

We use cookies and other tracking technologies (collectively, “Cookies”) that automatically track and collect information about your online interactions with us. For information about how we use Cookies and your options for managing Cookies, please see our Cookie Policy.

Minors.

Our Site and our offerings on the Site are not designed or intended for minors (individuals under the age of 13, or the legal age of majority in your jurisdiction), and we do not knowingly collect Personal Information from minors. If we learn that we have collected Personal Information from a minor, we will take steps to delete the data without notice as soon as possible.

HOW WE USE YOUR INFORMATION

We use information, including your Personal Information, for the following purposes:

To fulfill our contract with you. 

We may use your information to provide you with offerings, products, and services that you request, for example:

• When you sign up to participate in the Open edX Provider Marketplace or to enroll in a course offered on the Site, we use your Personal Information to create and manage your participation, account, and course enrollment.

For our legitimate business interests. 

We may use your information to:

• Improve our products and services including the Open edX platform and Open edX community programs and training services.
• Operate and improve the Site including performance and security.

• Contact you in connection with:
  • your engagement with our products and services, for example your enrollment in a training course.
  • your participation in one of our programs or the Open edX community
  • any accounts you may have with us
  • important policy or product updates, and
  • news and marketing about updates, events, and offerings that we think you’ll like.
• Provide customer service in response to your questions.
• Perform analytics that track Site usage against goals and mission.

For legal obligations.

We may use your information to exercise, enforce, and comply with legal rights and obligations as we believe reasonably necessary or appropriate, including without limitation responding to subpoenas, court orders, or other legal process and to protect your, our, or others’ rights, property, or safety.

With your consent.

We may seek your consent for additional uses of information, including Personal Information, and will use it only for the purpose described to you. All use of Personal Information is subject to applicable law.

We may use anonymous, de-identified, or aggregate information that does not reasonably identify you for any purpose, as permitted by applicable law.

HOW WE SHARE YOUR INFORMATION

With service providers.

We may share information, including Personal Information, with third parties to help us carry out the uses described above. For example, we may use third party support to help us create and offer training services and courses about the Open edX platform.

In some cases, the Site is integrated with third-party services or contains links to websites published by third parties. These third parties are responsible for their own privacy practices, so you should pay attention anytime you are redirected to a third-party website and be sure to review its privacy policy. For example, if you sign up for a GitHub account in order to participate in code development for the Open edX platform, your GitHub account will be managed and controlled by GitHub and subject to its terms and policies.

With other visitors to the Site. 

To create an interactive community environment, we may provide opportunities for you to submit content and information to share with other visitors to the site. This includes providing opportunities for you to join public community discussions by participating in forums and chat rooms and creating a public profile.

In the event of a major transaction or reorganization. 

We may share information in connection with evaluating and/or engaging in a major transaction such as a merger, sale, acquisition, reorganization, transfer of assets, bankruptcy, or change in ownership, and in such case(s), may share information also with affiliates and successors for their use consistent with this Privacy Policy.

With our related companies.

We may share information with related companies including affiliates, statutory members, subsidiaries, and other entities under common control and ownership.

With your consent.

We may seek your consent for additional disclosures of information, including Personal Information, and will share it only as described to you. 

In an aggregated or de-identified format.

We may share with partners, researchers, the public, and other third parties information and Personal Information that is anonymous, de-identified, or aggregated in a manner that does not reasonably identify you for any purpose, as permitted by applicable law.

RETENTION, STORAGE, AND SECURITY

Retention.

We may retain your Personal Information for as long as your account is active (should you have an account for one or more of our services and products) for as long as needed to provide you with products and services or fulfill the purpose for which it was collected; to maintain a record of your transactions for financial reporting, audit, and compliance purposes; and to comply with our legal obligations, resolve disputes, enforce our agreements, and as otherwise permitted by applicable law.

Storage.

We store information, including Personal Information, on servers located in the United States. However, information may be stored in other countries where we operate, and in countries where our service providers operate. If you are in the European Union, Switzerland, or other regions with laws governing data collection and use, you acknowledge that we may transfer, process and store your personal information in the United States and other countries, the privacy laws of which may be considered less strict than those of your region.

Security.

We use administrative, physical, and technical safeguards that reasonably and appropriately protect the confidentiality, integrity, and availability of the information that we collect, store, use, or transmit. Nonetheless, no method of transmission over the Internet, or method of electronic storage, is 100% secure; and therefore, we cannot guarantee its absolute security. While we work hard to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent “hackers” or other unauthorized persons from illegally accessing or obtaining information.

If we learn of a security breach involving our copy of your Personal Information, we may attempt to notify you electronically so that you may take appropriate protective steps. By using the Site or providing Personal Information to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If a security system breach occurs, we may post a notice on the Site homepage (openedx.org) or elsewhere on the Site and may send an email to you at the email address associated with you in our records. Depending on where you are located, you may have a legal right to receive notice of a security breach, involving your Personal Information, in writing.

HOW TO MANAGE YOUR PERSONAL INFORMATION

Manage Communications.

You may stop receiving promotional communications by following the “unsubscribe” instructions contained in the messages you receive or by contacting us directly at openedx@axim.org or privacy@axim.org. We may continue to contact you about non-promotional matters including administrative and transactional updates. You may update the email address we use for communications by contacting us directly at openedx@axim.org or privacy@axim.org. If you have an account for one of our products or services, you may update your email address within the account profile.

Manage Cookies.

You may manage cookies by updating your preferences in the “cookie settings” tool available on the Site. Please see our Cookie Policy for more information.

Manage Updates, Edits, Access, and Deletion.

To update, edit, access, and/or delete your Personal Information, or to request that we restrict our use of your Personal Information for any purpose, please contact us directly at openedx@axim.org or privacy@axim.org. If your request is related to an account that we manage, you may be able to update, edit, access, and/or delete your information directly within the account settings and profile. If you choose to restrict our ability to process Personal Information, and the processing is otherwise required to provide you with various services and products offered on the Site, we may not be able to provide you with those services or products.

Exceptions:

• We do not track or index every time or every place on the Site when or where a user may volunteer Personal Information, so we will not be able to help you locate or manage all such instances. We encourage you to use discretion before volunteering Personal Information on the Site.
• Deletion will not apply to historical activity logs or archives unless and until these logs and data naturally “age-off” our system.
• We cannot always delete records of past interactions and transactions including, for example, records relating to financial reporting, audit, and compliance.
• We will retain and use Personal Information as necessary to comply with our legal obligations, resolve disputes, enforce our agreements, and as otherwise permitted by applicable law

PRIVACY POLICY UPDATES

This Privacy Policy will be reviewed and updated from time to time. When changes are made, the updated Privacy Policy will be effective immediately upon posting on this page with an updated effective date. By accessing the Site after any changes have been made, you accept the modified Privacy Policy and any changes contained therein. In case you miss the notification referenced above, be sure to return to this page periodically to ensure familiarity with the most current version of this Privacy Policy.

CONTACT INFORMATION

If you have privacy concerns, have disclosed data you would prefer to keep private, or would like to access the Personal Information that we maintain about you, please contact us at privacy@axim.org. You may also write to us at: ATTN: PRIVACY, Axim Collaborative, One Broadway, 14th Floor, Cambridge, MA 02142 USA.

UPDATES

Effective Date	Description of update
2022-03-09	Replaced references to “edX” with “Axim Collaborative”
2022-05-12	Revised to replace references to “Axim Collaborative” with “us,” “we,” and “our,” and to clarify our current operations, for example: – The scope of intended users of the Site (i.e., not minors). – Rules of conduct that include not sharing passwords and not scraping content. – New information about user accounts and requirements for your use of these accounts. – New information about content on the Site, including the possibility that we may present personalized versions of content to different users, the possibility that we may block, remove or delete content at our discretion, and requirements of your and our use of other people’s content on the Site. – Clarification that we may terminate any use of the Site at our discretion. – DMCA rights and processes. – Our updated contact information.
2023-04-14	Replaced references to “Axim Collaborative” and “Axim Collaborative” with “Axim” and “Axim Collaborative”
2023-09-05	Clarified the scope of this Privacy Policy as not applicable to the Open edX software or its use in production by third parties.