Packback Privacy Policy

Last Updated: August 2025

Overview of the Packback Privacy Policy

Packback, Inc. (“Packback,” or “we” or “us”) operates an online platform that provides educational products and services for students (“Student Users”) and educators (“Educator Users,” and collectively with Student Users, “Users”), through its Packback.co website and other websites, domains, sub-domains and technology products associated therewith (collectively, the “Packback Website”) and all other products and services offered by Packback (together with the Packback Website, the “Packback Platform”). The Packback Platform contains text, photographs, illustrations, video, audio and/or any other media or content from, and on behalf of, Packback (“Platform Content”) and text, photographs, illustrations, video, audio and/or any other media or content from Users (“User Generated Content”). Capitalized words that are not defined herein have the definitions set forth in our Terms of Use.

Packback is committed to protecting your privacy. To support fearless curiosity, we are committed to providing a safe, secure platform that protects our Users’ privacy and personal information.

As an education company that provides services and support to students, we are particularly aware of the sensitive nature of some student data, and we have worked hard to ensure compliance with The Family Educational Rights and Privacy Act (“FERPA”), Children’s Online Privacy Protection Act (“COPPA”) and other applicable laws and to build a system that can accommodate the needs individual schools where definitions of personally identifiable information or personal information may differ. If at any time you have questions or concerns about the collection, storage or usage of your personal information or User Generated Content, or if you notice any oversights in our Privacy Policy, please contact us at privacy@packback.co. We are a young company and are continuously working to better support and serve the security needs of our growing user base and educational institution partners (“Educational Institutions”).

This Privacy Policy explains our collection, use and any potential disclosure of your information. The terms within this Privacy Policy apply to all personal information collected by Packback on the Packback Platform.

The Packback Platform may be accessed in the United States and abroad. In such cases, certain data and information will be transferred to the United States. For personal information protection purposes, Packback is the controller and, unless otherwise noted, is also the processor of the personal information. User account information remains in your Packback account until you choose to delete it, or until your account has been inactive for 8 years, whichever occurs first. This period of time ensures your information is available to you across your entire academic career.    

If you are using the Packback Platform outside of the United States, your data and the information collected may be subject to the data protection laws of the country in which you are located, regardless of whether or not your data is transferred to the United States. To the extent permitted by applicable law, if you would like to request to review, correct, restrict or delete personal information that you have previously provided to us, object to the processing of personal information, or you would like to request to receive an electronic copy of your personal information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), please contact us at privacy@packback.co. We will respond to your request in accordance with the applicable law that governs the collection, use and deletion of your data and information. The requested deletion will be as comprehensive as possible but is always subject to issues outside of our control, including applicable regulations and laws, your actions and the actions of third parties. It is important to note that we may retain a copy of the information for archival purposes and to avoid identity theft or fraud. Certain users may have additional personal information rights and choices based on where they live. Please see section on “Your Data Rights” for more information.

What Information We Collect and How We Collect It

We collect several types of information from you and about users of the Packback Platform, including information: 

• By which you may be personally identified such as name, email address.
• That is about you but does not individually identify you, such as about your internet connection, the equipment you use to access the Packback platform, and usage details.  

We collect this information:

• Directly from you when you provide it to us. 
• Automatically as you use the Packback Platform. 
• From third parties, for example, a Parent, instructor, or Authorized School Administrator if you are a student. 

Information You Provide to Us

The information we collect on or through our Platform may include: 

Collection of Necessary Subscriber Information to Create an Account

By using Packback products and accessing the Packback Platform, either on your own or through a class (either as a student user, instructor, or administrator), some information is collected about you to be able to create a user account and fulfill the necessary functions of the purpose of the Packback Platform. See sections on FERPA and COPPA for complete details on our FERPA and COPPA compliance.

You may always choose not to provide subscriber information (by opting not to create an account) and may choose to remove an account that was created for you by your instructor or the Packback team at any time, but if you so choose, certain products and services may not be available to you . We intentionally require as little subscriber information as possible to be able to create your user account and provide you with the services of our site. You can update your personal information on the Packback Platform at any time.  In order for the purposes for which the data is collected to be realized, it is the responsibility of the user to keep this information up to date.

By either registering for your own account on Packback, or by accepting an account created for your behalf, you consent to Packback collecting and storing the required subscriber information to create your account:

• Information collected when you register:
• Your first and last name;
• Password;
• Email address;
• School name;
• Grade level;
• Information processed when you make a purchase including your credit card number and billing address. (Note: this information is processed in Level 1 PCI compliant processor Stripe, to further protect your billing information and online security, but since Packback is not able to see any of this information, it is not collected or stored on the Packback Platform.)     

Packback takes steps to minimize the collection of personal data from the product to only what is necessary to provide the services.

Your continued usage of the Packback Platform represents your continued consent to the Terms of Use and this Privacy Policy.

To learn about Packback’s commitment and adherence to FERPA and COPPA in protecting and storing all student information, please read the sections “FERPA” and “COPPA”, respectively, below.

You will be explicitly informed if there is any intent to use your subscriber information combined with your User Generated Content in any way other than what is outlined in this document. Any additional usage will require your explicit secondary opt in.

User Generated Content

A registered Packback User may generate and publish their own User Generated Content on the Packback Platform. Please see the section on “Use of ‘User Generated Content’” for more information on how this content is stored and shared.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with the Packback Platform, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and usage patterns including: 

• Details of your visits to the Packback Platform, including traffic data, logs, access times, referring website, and other communication data and resources that you access while on the Packback Platform. 
• Information about your computer and internet connection, including your IP address, operating system and browser type. 

The information we collect automatically may include personal information. It helps us improve our Platform and deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns
• Store information about your preferences. 
• Recognize you when you return to the Packback Platform. 

The technologies we use for this automatic data collection may include: 

• Cookies. A cookie is a small file placed on your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of the Packback Platform. 

Information we Collect from Others

We may collect information about you from others, such as instructors, Authorized School Administrators or Parents of Child Users or Minor Users. This information may include subscriber information and  data relating to violations of our Terms (we may receive information from third parties, law enforcement, and others, about potential violators of our Terms of Service). 

Age Restrictions

We do not intend to solicit or collect personal information from anyone under the age of 13 (a “Child User”) and/or who is otherwise unable to enter into a contract (a “Minor User”) without consent from such the parent or legal guardian of such Child User or Minor User, as applicable (“Parent”), or from an Authorized School Official. Child Users and Minor Users may only use the Packback Platform with consent from a Parent or Authorized School Official. If you believe we might have any information from or about a person who is a Child User or Minor User without legal consent, please contact us at privacy@packback.co.

Use of Information We Collect

Packback, its affiliates or its licensors may access and use the information you provide to us, including User Generated Content Data, the information we collect automatically, and the information we collect from third parties, and learnings about Users’ use of or interaction with the Packback Platform (“Learnings”) to develop, operate, improve and support its products and services (including, without limitation, the Website Services and the Platform) and for other lawful business purposes, including without limitation benchmarking and reports, and analytic, statistical, security, quality control, and similar purposes (“Permitted Purposes”). 

As part of the Permitted Purposes, the Platform uses artificial intelligence (or AI) to help Packback more efficiently analyze and identify trends in usage, which Packback then uses to modify and improve its instructional materials and the Packback Platform as a whole. We utilize application program interfaces from OpenAI to help power the AI functionality of our Services. No AI provider we use has the right to train models on any data processed on Packback’s behalf.  Any data sent through these APIs is retained for up to 30 days solely for abuse and misuse monitoring before being permanently deleted—unless required by law to retain it longer. Packback’s AI does not create, include or generate personal or individual-specific data. Packback does not use any data from Child Users or Minor Users in connection with Packback’s AI. Packback will own all right, title and interest in all aggregated and anonymized data and information (in each case, that does not include personally identifiable information from any Student User and from which personally identifiable information of any Student User cannot be derived) generated in connection with the Permitted Purposes. 

Use of Subscriber Information

Packback collects and uses the above outlined subscriber information to:

• Create and manage your membership account;
• Process your transactions;
• Provide customer service;
• Perform research and analysis aimed at improving our products, services, curriculum, educational outcomes, and technologies;
• To display content that is customized to your preferences;
• To identify your uploaded content as your own authenticated content for the purposes of tracking your usage for grading purposes; 
• If you are an employee, contractor, or paid contributor for Packback, to compensate you and to prepare tax information slips; 
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection; 
• To communicate with you about your transactions, new products and services; and,
• For any purpose for which you provide consent. 

We may send transaction-related communications such as welcome letters, billing reminders, and purchase confirmations. If you do not wish to receive surveys or marketing communications, you may adjust your “Personal Information Preferences” as described below or follow the “unsubscribe” instructions included within each email communication. Please keep in mind that if you choose not to receive marketing communications, you may continue to receive transactional or account communications (e.g., confirmation emails, password reset emails, digest emails, etc).

Use of User-Generated Content

Packback collects, stores and uses “User Generated Content” to:

• Provide the core functionality of the Packback Platform, including displaying User Generated Content to other Packback Users to read and respond to;
• Combining subscriber information with User Generated Content data to allow School Officials to assign a grade to a student’s participation on the Packback Platform; and

To share in the limited and protected ways outlined in the section entitled “How and When We Share Your Information.”    

FERPA

FERPA stands for the Family Educational Rights and Privacy Act (20 U.S.C. 1232g, 34CFR§99) and is designed to ensure that student’s personally identifiable education information is protected.

Packback takes FERPA compliance extremely seriously, and we have designed our system to provide options to accommodate each school’s definition of Directory Information and/or Personally Identifiable Information (PII).

In the course of Subscriber’s use of the Services, personally identifiable information about students (“Student Personal Data”) may be disclosed to Packback. Packback acknowledges that it will be considered a “School Official” (as outlined in FERPA) and will comply with the requirements in FERPA concerning the confidentiality and release of Student Personal Data. Packback officers, employees, and agents of Packback who access Student Personal Data may use such data only for the purposes for which such data has been made available to Packback and ways outlined within this Privacy Policy.

Packback’s definition of “Student Personal Data” on Packback includes (as relevant for Packback), student name, email address, course title/information, and final participation grade information.

User Generated Content posted by student Users in the Packback Questions forum–when completely separated from any identifiable information about the student who posted the content–would not be considered Student Personal Data. Our system gives students the right to control who can view their subscriber information combined with their student posted content, and we have a sophisticated authorization and privacy system that prevents any unauthorized user from connecting student posted data to any subscriber information at the backend API level.

Subscriber information is not simply “obscured” on the website, but is actively separated at the server level and cannot be connected to User Generated Content unless requested by an authorized School Official (with proper permissions in the Packback system).

Please read the section entitled “How and When We Share Your Information” to learn more about the limited ways in which we share and or use the collected information.

COPPA

COPPA stands for the Children’s Online Privacy Protection Act (15 U.S.C. 6501, 16 CFR Part 312) and is designed to protect the privacy of children under the age of 13.

Packback takes COPPA compliance extremely seriously, and we have designed our system to ensure that Packback obtains the consent of a Child User’s Parent or an Authorized School Official prior to collecting personal information online from such Child User. Packback does not knowingly permit Child Users to register directly for the Packback Platform without the verifiable consent of a Parent or an Authorized School Official. If Packback learns that the personal information of a Child User has been collected on the Packback Platform without legal consent, then Packback will take appropriate steps to delete such information.  If you are a Parent of a Child User and discover that your child has an account on the Packback Platform without your consent, please alert us at privacy@packback.co.  In compliance with COPPA, we do not require a child user to provide any personal information beyond what is reasonably necessary for them to participate in Packback’s educational services.

We permit the school to create Child User and/or Minor User accounts, as applicable, when the Packback Platform is used by a school in the classroom for an educational purpose. The school may provide consent for Packback to collect personal information of a Child User or Minor User, as applicable, for this purpose. Schools may create a Child User or Minor User account, as applicable by adding students to the Packback Platform through our registration process for schools. A school may create logins/passwords for each individual Student User using tools that we provide. We obtain, and where appropriate, require institutions to obtain, verifiable parental consent. When Packback is used by a School in an educational setting, we rely on the School to provide the requisite consent, on behalf of the Parent, for Packback to collect information from a School User under the age of 13 for educational purposes. 

Packback will defer to the institution’s authority regarding data access, updates, or deletion requests. Parents should direct such requests to the school or district, which can then coordinate with Packback.

If you are an Educator User and you register an account for a Child User or a Minor User, you, individually and on behalf of the Educational Institution , represent and warrant that you have received express consent from such Child User’s or Minor User’s Parent or have provided such consent as an Authorized School Official for you to register the Child User or Minor User for access to or use of the Packback Platform and for you to provide to Packback the information you disclose in connection with the registration of such Child User or Minor User.  Without limiting the foregoing, you further agree, individually and on behalf of your Educational Institution, to be bound by these terms on behalf of such Child User or Minor User.

How and When We Share Your Information

Disclosing the Personal Information We Collect About You

Packback does not sell your personal information to any third parties.  No student profile or student work is made available or visible to the public

Except as set out in this Privacy Policy, Packback does not disclose your personal information to any third parties without your affirmative consent through a secondary optional opt-in process.

We disclose subscriber information to third-party service providers who perform necessary services on our behalf to provide you with the best and most secure experience possible, including, but not limited to, to handle the processing of payments, to provide data storage, to host websites, to fulfill orders and shipments, to conduct audits, etc. Those third-party service providers (i) are only permitted to obtain the personal information they need to provide the service, (ii) are contractually obligated to protect personal information to the same extent as Packback, and (iii) are contractually prohibited from using it for any other purpose.

We may disclose subscriber information to law enforcement agencies if required to do so by law, including in response to a valid subpoena, warrant, or legal process. Such disclosures will be made in compliance with applicable laws and only to the extent necessary to fulfill legal obligations.

Over time, Packback may grow and reorganize. We may share your information, including personal information with affiliates such as a parent company, subsidiaries, joint venture partners or other companies that we control or that are under common control with us, in which case we will require those companies to agree to use your personal information in a way that is consistent with this Privacy Policy.  

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In the event of a change to our organizations such that all or a portion of Packback or its assets are acquired by or merged with a third-party, or in any other situation where personal information that we have collected from users would be one of the assets transferred to or acquired by that third-party, this Privacy Policy will continue to apply to your information, and any acquirer would only be able to handle your personal information as per this policy (unless you give consent to a new policy). 

In the unlikely event that Packback goes out of business, or files for bankruptcy, we will protect your personal information, and will not sell it to any third-party.

Packback User Generated Content

Students can have social interactions with others in their classes (via replying to discussion assignments) and Packback moderates those interactions. By posting User Generated Content through your account on Packback, this Content will be subject to this Privacy Policy and our Terms of Use. You, as the original poster of your content, retain non-exclusive ownership over your User Generated Content and may edit or delete your User Generated Content at any time, as well as use your own content again in any way.

By uploading User Generated Content, you also give Packback a perpetual, non-exclusive, non-transferable and royalty-free license to use such User Generated Content for the Permitted Purposes.

Only you, as the original author of the content –and no other Member– shall ever have the right to sell for any value your User Generated Content (except as you expressly agree in writing), except that Packback may use such User Generated Content for the Permitted Purposes.

Personalized Advertising and Marketing

Packback does not share your personal information with third parties for their own marketing purposes, including direct marketing. We do not permit contextual advertisements, marketing, or other third-party advertising and promotion in our services. 

We do not use or disclose Student Data for targeted advertising purposes. Specifically, personalized advertising (ads based on a user’s personal information) is not used or displayed in Packback’s products. We are committed to protecting the privacy and data of our students. We do not share student data with third-party advertisers or use it to create profiles for advertising purposes.

General Usage Questions

If you are a school administrator and you would like more information about how we protect student privacy, autonomy and control over their data, please contact us at privacy@packback.co.

Choices About How We Collect, Use and Disclose Your Information

Your Right to Decline Consent

If you are being asked to use Packback products for a class, but do not consent to the Packback Terms of Use and Privacy Policy, please contact our team at privacy@packback.co; we will be happy to work with you to answer your questions and make best effort to accommodate your needs. If you would like to review or revise information that you previously provided to us, you may access and change your personal information in the “Account Settings” section of the website. You may also, at any time, request a deletion of your account. We will respond to such request within the applicable period prescribed by law (and usually within 48 hours). The requested deletion will be as comprehensive as possible but is always subject to issues outside of our control, including applicable regulations and laws, your actions and the actions of third parties. It is important to note that we may retain a copy of the information for archival purposes and to avoid identity theft or fraud.

As a User of Packback,  an account deletion will remove all record of your personal information from the Packback Platform (email, name, posting statistics, etc.).At any time, you are able to manage your own User Generated Content by navigating to your Profile. You can edit and delete your own posts.

Personal Information and Email Preferences

Packback respects your right to make choices about the use and disclosure of your personal information. If at any time you have questions or concerns about the collection, storage or usage of your personal information or User Generated Content, please contact our customer support team by emailing privacy@packback.co.

If you choose not to receive marketing communications, you may request to be unsubscribed at any time. Please be advised that you may not receive transactional, password reset, or account communications (e.g., confirmation emails and account balance statements). You can request to be re-subscribed at any time by emailing us at privacy@packback.co.

Your State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. 

To learn more about California residents’ privacy rights, please see the section below entitled “Privacy Notice for California Residents.” 

Certain states, such as California, New Jersey, Delaware, Maryland, Minnesota, and Oregon provide (now or in the future) their state residents with rights to: 

• Confirm whether we process their personal information. 
• Access and delete certain personal information. 
• Correct inaccuracies in their personal information, taking into account the nature of the information and the processing purpose. 
• Data Portability. 
• Either limit (opt-out of) or require consent to process sensitive personal data. 
• Opt out of targeted advertising. 

More Information on International Data Protection Rights

Certain Users may have additional personal information rights and choices based on where they live. We have tried to provide links to websites that provide more information below. If you feel that this list does not cover your rights, please send an email to privacy@packback.co.

If you are a Canada resident, Canadian law may provide you with additional rights regarding our use of your personal information. To learn more about your Canada privacy rights, visit https://www.priv.gc.ca/en/.

If you are a resident of the European Union or European Economic Area, the General Data Protection Law (“GDPR”) may provide you with additional rights regarding our use of your personal information. To learn more about your GDPR privacy rights, visit https://eugdpr.org/the-regulation/.

You also have the right to lodge a complaint with the supervisory authority of your habitual residence, place of work or place of alleged infringement if you consider that the processing of your personal data infringes applicable law.

A list of European Union data protection authorities is available at:http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080 .

Exercising Your Privacy Rights

You may edit any of your Personal Information in your account on the Packback Platform, including contact information and/or notification settings, by editing your account profile. 

You may request that we delete your account information by deleting your account from your profile page, but please note that we may be required (by law or otherwise) 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 account information is deleted, it will be erased from the active database but may remain in our archives for a limited amount of time. We will otherwise retain your information for as long as your account is active, as needed to provide you with the Services you have requested, or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreementsIt is important to note that we may retain a copy of the information for archival purposes and to avoid identity theft or fraud

To exercise any of your other privacy rights, please contact privacy@packback.co. To appeal a decision regarding a consumer rights request, please contact privacy@packback.co. We will respond to your request or appeal in accordance with the applicable law that governs the collection, use and deletion of your data and information. 

Security of Your Personal Information

The security of your personal information is important to us. We follow generally accepted industry best practices to help protect your personal information including without limitation:

• Limiting access to your personal information to those of our employees who require it to provide services to you;
• Requiring employees to sign confidentiality agreements to protect customer and other confidential information;
• Require complex passwords and failed login lockouts protect user information.
• Ensuring that third-party service providers sign confidentiality agreements to maintain the confidentiality of your personal information and not to use it for any unauthorized purposes;
• All customer data is encrypted at rest with AES-256 and in transit via TLS.
• Not storing your billing information or credit card information within our system directly, but instead using Level 1 PCI compliant processor Stripe to store all payment information;
• Rigorous evaluation of all third-party service providers before implementation;
• Annual Security Reviews internally to reevaluate all service providers and our system, to continue to ensure the highest level of security;

No method of transmission over the Internet, or method of electronic storage, is ever 100% secure. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security. If a password is used to protect your account and personal information, it is your responsibility to keep your login credentials confidential. We will notify you of a security incident as required by applicable law.

Other Details About Privacy and Data at Packback

Links

We (Packback) or Users on the Packback Platform may share “link” to websites, including those of our subsidiaries and third-party content providers, that have different privacy policies and practices from those disclosed here. We can assume no responsibility for the policies or practices of such linked sites and encourage you to become acquainted with them prior to following links.

Content Posting Agreement and the Use of Copyrighted Content

By posting User Generated Content on Packback, you agree to the Content Posting Agreement as outlined here:

• You assert that you are not posting Copyrighted Content without proper licensing for sharing, distributing or otherwise remixing;
• If you share content with a Creative Commons License, you agree to provide proper attribution as the “Source” when posting;
• You will not post inflammatory, inappropriate, derogatory, or otherwise egregious content that limits or detracts from other users’ ability to have a safe and professional educational environment on the platform.

If you do post Copyrighted Content, Packback claims no responsibility or ownership over the Copyrighted Content. We will look for Copyrighted Content and remove it and will comply with a removal request from any owner of inappropriately posted Copyrighted Content promptly.

By posting User Generated Content on Packback, you agree to give Packback the right to Edit, Delete or “Moderate” your User Generated Content to ensure compliance with the Community Guidelines and Content Posting Agreement without limitation.

Privacy Personnel

We have personnel at Packback who are accountable for our policies and practices with respect to the management of personal information. You may forward any questions, comments or complaints that you might have about this Privacy Policy to privacy@packback.co. We are happy to answer any questions.

Contests or Giveaways (If applicable)

If you have entered into and/or won a Packback contest, we or a contest sponsor may publish your name and city of residence. Information about our customers, including personal information, may be disclosed as part of any merger, acquisition, or sale of the company and/or its assets, as well as in the unlikely event of insolvency, bankruptcy, or receivership, in which personal information would be transferred as one of the business assets of the company. We will notify you of such an occurrence as described in the “Changes to This Privacy Policy” section below. We reserve the right to disclose your personal information if required or permitted to do so by law.

Where Your Information is Physically Stored

Personal information collected by Packback may be stored and processed in the United States or any other country in which Packback or its affiliates maintain facilities, and by providing us with your personal information and using the Packback Platform, including our sites or services, you consent to any such transfer of information outside of your country. If you would like to exercise any of your personal information protection rights (including the right to have your personal information deleted), please contact us using the “Contact Information” below.

We employ the use of cloud-based storage with distributed physical servers through companies with the highest tier compliance, security and reputability. Currently, most of our servers are in the United States. Data of Users based in Canada are stored on servers in Canada; although, your email, name, post data, (including User Generated Content), and other relevant information may be sent to US-based companies we use, so we can answer your customer support emails, send you important emails from the system, etc.

Changes to this Privacy Policy

While we reserve the right to change the terms of this Privacy Policy at any time, we will make every best effort to only make material changes to the Privacy Policy between class terms to avoid any potential disruption.

When we make changes, we will revise the “last updated” date at the top of the policy. If there are material changes to this statement or in how Packback will collect or use your personal information, we will notify you by prominently posting a notice of such changes here or on our home page, or by sending you an email. We encourage you to review this Privacy Policy whenever you visit the Packback Platform. If applicable law requires your affirmative consent, we will require such affirmative consent the next time you access the Packback Platform.

Contact Us

Packback welcomes your comments, questions, and concerns. Please contact us at privacy@packback.co or at our mailing address below:

Packback
125 S Clark St, Suite 1150,
Chicago IL 60603     

We have appointed a Data Protection Lead responsible for overseeing our internal privacy practices and ensuring appropriate safeguards are in place for handling personal data. You can contact the Data Protection Lead at privacy@packback.co.

California Consumer Privacy Act (CCPA) Privacy Notice

This portion of our Privacy Policy applies only to residents of the state of California and applies only to the extent of any inconsistency with the information above. 

Categories Of Personal Information Collected About Consumers

In the 12-month period before the effective date this Privacy Policy, Company collected the following categories of personal information about consumers:

• Identifiers such as real name, online identifier, Internet Protocol address, email address, and account name.
• Internet or other electronic network activity information regarding a consumer’s interaction with the Packback Platform.
• Education information. 

Collection of Sensitive Personal Information

We may also collect or process sensitive personal information as necessary to operate our business, to comply with our legal and regulatory obligations, and to provide our services to you. We may collect the following types of sensitive personal information from you:

• Account log-in in combination with any required security or access code, password, or credentials allowing access to an account.

We do not use or disclose your sensitive personal information for purposes other than those permitted by California law.

Categories of Sources from Which Personal Information Is Collected

• Directly from you, for example, when you fill out a form on the Packback Platform or sign up for an account with us.
• Indirectly from you, for example, from observing your actions on our websites and from your devices.

Purpose for Collecting Personal Information 

We have collected and used your information for the following purposes:

• Providing the Platform to you. 
• Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes.
• Debugging to identify and repair errors that impair existing intended functionality.
• Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with the business, provided that the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business.
• Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business.
• Undertaking internal research for technological development and demonstration.
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

Disclosure of Your Personal Information

Within the last 12 months, we may have shared the categories of personal information below to the following categories of third parties for the following purposes: 

• Identifiers, disclosed to service providers, used for providing the service to you
• Internet or other electronic network activity information, disclosed to service providers, used for providing and improving the service.

Your California Privacy Rights

If you are a California resident, you have the following rights regarding your personal information.

Right to Access. You have the right to confirm whether we are processing your personal information and to obtain a copy of the personal information we have collected about you. If requested, we will provide this information in a portable and, if technically feasible, readily usable format.

Right to Know. You have the right to know about personal information that we have collected, disclosed, shared, or sold: 

• The categories of personal information collected;
• The categories of sources from which we collected personal information;
• The business or commercial purposes for which we use the personal information;
• The categories of third parties with whom we share the personal information; 
• The categories of information that we sell or disclose to third parties; and
• The specific personal information we collected. 

Right to Delete. You have the right to request that we delete your personal information. Upon verifying your identity and the validity of your request, we will delete your personal information from our records and instruct our service providers, affiliates, or third parties to delete your information as required by law. We may deny your deletion request if retaining the information is permitted under law. 

Right to Correct. You have the right to correct inaccuracies in your personal information. In certain circumstances, we may not be able to satisfy this request depending on the nature of the personal information and purposes for maintaining it.

Right to Opt-Out. You have the right to opt out of certain types of personal information processing, including the “sale” of personal information, sharing, or use of personal information for targeted advertising and any processing of personal information for decision-making purposes that produce legal or similarly significant effects. We do not sell or share your personal information for targeted advertising or profiling. 

How to Exercise These Rights

You can exercise any of your CCPA rights described in the previous section by contacting us at privacy@packback.co.

Where permitted or required by law, please note that we may take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. In connection with such verification, we may ask you to provide evidence of access to the user account in question (for example, via access to its email address) before responding to any requests. We may limit our response to your exercise of the above rights as permitted by law. 

We may not discriminate against you for exercising any of your rights under California law.  This means that we may not deny you services, or charge you different prices or rates for services or provide you with a different level or quality of services (or suggest that we will do so), in response to a request made under California law. If you are an employee, applicant, or independent contractor, we may not retaliate against you for the exercise of your rights. However, we may charge different prices or rates, or provide a different level or quality of services, where that difference is reasonably related to the value provided to us by your personal information.

You may designate an authorized agent to make a California rights request on your behalf. To designate an authorized agent, you must provide the agent with written permission to submit the request.  We may still require you to confirm that you have authorized an agent to act on your behalf and to verify your identity directly (subject to certain exceptions) as permitted by law. We may refuse a request if the agent does not provide adequate proof of their authorization as permitted by law.

Contact Us

If you have questions about our business’s privacy practices, you may contact us at privacy@packback.co.