We at DopaGE, INC (“DopaGE,” “we,” “us,” “our”) care about you (“you”, “user”, “learner”, and/or "business professional" as appropriate) and how your personal information is used and shared. We take your privacy seriously and are committed to creating a safe and secure environment for learners of all ages. This Policy is designed to help you understand what information we collect, why we collect it, and what we do with it. Thank you for taking the time to carefully read it.
1 | ABOUT DOPAGE
DopaGE is an overdose prevention education company. We empower college learners with the skills necessary to reduce harm and death related to substance use. This Policy applies to all DopaGE products, services, and websites (collectively the “Service”). This Policy describes how DopaGE collects, uses and discloses the information it collects via the Service. In some instances, our Service may be accessible via a third party website, including that of an Authorized Entity (defined below). This Policy does not apply to how a third party or an Authorized Entity collects, uses, or discloses any information related to Service users.
By using the Service, you acknowledge that DopaGE will handle your personal information as described in this Policy. Your use of our Service, and any dispute over privacy, is subject to this Policy, which may from time to time be amended.
DopaGE Websites
This Privacy Policy applies to all websites owned and operated by DopaGE, INC
2 | PERSONAL INFORMATION WE COLLECT
DopaGE’s digital learning platform offers educational courses on overdose prevention in the Higher Education market. We may collect information about you directly from you and automatically through your usage.
Information We Collect Directly from Learners:
Where you register with us, or communicate to us, depending on the Service, we may collect the following information:
Contact information and common identifiers: Such as name and email address;
Login details: including username and password;
Educational details: including information about a user’s level of education and academic institution;
Demographic information: Such as age, sex, and gender;
Preferences: Based on user-specific implementations and information about user activities within the Service, including information about the content modules a user views, starts or finishes (including data and time stamps), assessments or scores, and related information, and other information about a user’s activities and use of the Service in order to ensure our digital learning is appropriately teaching overdose prevention skills.
Where additional data is collected for a specific course, we will provide further details in our contractual terms.
DopaGE educational assessments and surveys may ask questions based on race and ethnicity. This information is considered “sensitive” or “special category” data under applicable privacy laws; therefore we will only collect it where you choose to provide this information and consent to us receiving it – the questions are always optional.
When we receive the surveys, we take steps to fully de-identify it and will only share responses on a fully de-identified and aggregated basis. In our Higher Education market, DopaGE extracts information from survey data before analyzing such data in an aggregated research setting.
Information We Collect Automatically
We collect information automatically about users via a variety of methods, such as cookies, web beacons, JavaScript, and log files. This information may include user IP addresses, browser types, domain names, device type, time stamp, referring URL and other log file information,; user activities within the Service,; aggregate and statistical information regarding overall server/visitor traffic and navigation patterns for the Service. Web servers collect this type of basic information automatically as part of Web log processes. For more information, see the “How We Use Cookies and Analytics” section below.
Information Business Professionals May Provide:
If you want to request a demo of any Service and/or have a conversation with one of our product experts to learn how DopaGE can power your education initiatives, you can provide us with:
Contact Information: first name, last name, email address, phone number;
Job Details: job title and a note of which institution you work with;
Communications preferences.
Information Obtained from Third Parties/Public Sources:
We use third party service providers to enhance and enrich our marketing database of business professionals who have requested further information on our products. They may use information that is made public by you for example via LinkedIn.
3 | HOW WE USE PERSONAL INFORMATION
DopaGE generally uses the information we collect as follows:
To provide the Service directly to learners (where applicable).
To create log-in details for learners (where we are contracting with a sponsoring organization such as a higher education institution i.e. a university), to communicate with you about your use of the Service (including via email); to respond to your inquiries; to send you surveys; to fulfill your requests; and for other customer service or internal purposes.
To troubleshoot any technical issues you might experience while using our Service.
Where you are a business professional (e.g. sponsoring organization such as a higher education institution i.e. a university), to send you communications about digital courses, services and other information we think may interest you where you have requested a demo and with additional information where we have appropriate permissions. We may also enrich our marketing database using publicly available information to tailor our communications and ensure these are relevant to your industry and of interest to you.
To better understand how users access and use our Service, in order to improve our Service, to respond to user desires and preferences, and for other research and analytical purposes.
To develop aggregated reports and related analysis regarding user activities.
To tailor the educational content and information that we may send or display to you, to offer personalized help and instructions, and to otherwise personalize your learning experience while using our Service.
To comply with applicable legal obligations, including responding to a subpoena or court order.
Where we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our Terms of Use or this Policy.
4 | SHARING OF PERSONAL INFORMATION WITH THIRD PARTIES
DopaGE does not sell your personal information, or share your personal information for the purposes of targeted advertising.
We share the information we collect with the following third parties for the following business purposes:
Authorized Entities. If you access the Service through, or are granted access to the Service by, a school, school district, college, university, person, institution, employer, or other organization (an “Authorized Entity”), we will share the information we collect about you with the Authorized Entity or its representatives. Such information may include: course progress/completion; assessment scores; email address; user ID/identifying tag or username (if applicable); and additional aggregated data the Authorized Entity requests.
Third-Party Sponsors. In the Higher Education market, DopaGE works with third-party sponsors to bring the Service to some users free-of-charge. In such situations, DopaGE will only share anonymized and aggregated user information. This anonymized and aggregated information may include demographic and geographic profiles to assess the learning progress of categories of Service users.
Legal Disclosures. We may disclose a Service user’s information (including personal information) where we believe that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a warrant or administrative request, a court or regulatory order, or other valid legal processes. We may also disclose personal information where we believe it is necessary to identify, contact or bring legal action against someone who may be violating the Terms of Service for our Service, to detect fraud, for assistance with a delinquent account, as evidence in litigation in which we are involved, or to protect the safety and/or security of our users, the Service or the general public.
Service Providers. We may employ independent contractors, vendors and suppliers to provide specific services related to the Service, such as hosting and maintaining the Service, providing credit card processing and fraud screening, and developing applications for the Service, email services and marketing enrichment services.
Business Transfers. We reserve the right to transfer information (including personal information) to a third party in the event of a sale, merger or other transfer of all or substantially all of the assets of DopaGE or any of its Affiliates (including as part of a bankruptcy proceeding). We may disclose personal information about Service users to our affiliated companies. Our affiliates’ use of your personal information will be in accordance with the terms of this Privacy Policy.
Aggregate and De-Identified Information. We may also provide aggregate, anonymous or de-identified information about users and the Service for marketing and research purposes. For example, we might inform third parties regarding the number of unique users who visit the Service, the demographic breakdown of our registered users of the Service, and the educational progress of categories of users.
5 | HOW WE USE COOKIES AND ANALYTICS
We use cookies and other tracking mechanisms to track information about your use of our Service.
Cookies. We use cookies to track visitor activity on our platform. A cookie is a text file that a website transfers to your computer’s hard drive for record-keeping purposes. We, and our service providers, use cookies to track user activities on our Service, such as the pages visited and time spent on our Service. Most browsers allow users to refuse cookies. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. However, many of our Services will not function properly with cookies disabled.
Local Shared Objects. We may use local shared objects (“LSOs”), such as Flash LSOs to store your preferences and to personalize your visit. LSOs are different from browser cookies because of the amount and type of data stored. Typically, you cannot control, delete, or disable LSOs through your web browser. For more information or to learn how to manage your Flash LSO settings, go to the Adobe Flash Player Help Page, choose “Global Storage Settings Panel” and follow the instructions.
Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages and cannot be disabled through your browser. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Service to, among other things, track the activities of users, help us manage content, and compile statistics about usage. We, and our service providers may also use clear GIFs in HTML emails to our customers to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
Third-Party Analytics. From time to time we may use various tools to evaluate usage of our Service. We use these tools to help us improve our services, performance, and user experiences. These entities may use cookies and other tracking technologies to perform their services. By way of example, Google Analytics is one of the tools we may use. To learn more about Google’s privacy practices, please review the Google privacy policy at https://www.google.com/policies/privacy/ (opens in new tab). You can also download the Google Analytics Opt-out Browser Add-on to prevent data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout (opens in new tab).
6 | HOW WE PROTECT PERSONAL INFORMATION
DopaGE implements reasonable and appropriate physical, administrative and technical safeguards to help us protect your personal information from unauthorized access, use and disclosure, and to maintain accuracy and ensure the appropriate use of your information. Where appropriate, these safeguards include encryption. However, no data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk. We believe that we have put in place the appropriate procedures to help safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect online.
De-Identified Data. DopaGE will maintain and use de-identified data only in a de-identified form and not attempt to re-identify de-identified data.
7 | US CONSUMER PRIVACY RIGHTS
Five states afford consumers in those states additional privacy protections. These states are:
The California Consumer Privacy Act (the “CCPA”);
The Colorado Privacy Act (the “CPA”);
The Connecticut Act Concerning Personal Data Privacy and Online Monitoring (the “CTDPA”);
The Utah Consumer Privacy Act (the “UCPA”); and
The Virginia Consumer Data Protection Act (the “VCDPA”).
The additional privacy protections provided by those laws include: the right to know what collected information businesses disclose; the right to access a copy of your data; the right to request deletion or correction of your data; and the right to opt out of the sale of your data or the sharing of your data for purposes of targeted behavioral advertising. Businesses can’t discriminate against you for exercising any of these rights.
Exercising Your Privacy Rights. To request access to or deletion of your personal information, or to exercise any other data rights under the laws set forth above, please see our Data Subject Rights Requests page at https://dopa.ge/personal-data-requests. We will verify your identity where required prior to fulfilling your request, which may require government identification. Authorized agents may be used to submit rights requests, in which cases we will take steps to verify the consumer’s identity and that the agent has authority to act on the consumer’s behalf.
Response Timing and Format. We will respond to a consumer privacy request within the time period required under any applicable privacy laws. If we require more time, in accordance with applicable privacy laws, we will inform you of the reason and extension period in writing.
8 | CHANGES TO OUR PRIVACY POLICY
DopaGE may amend this Privacy Policy from time to time. We will provide notice of any material changes made to our Privacy Policy by prominently posting the revised Policy with an updated date of revision on our homepage. We encourage you to check this page periodically for any changes. If we make any material changes that affect information we have previously collected about you, we will provide you with notice (or in the case of a child, to your parent or legal guardian - or to your school/educational institution who will make it available to you or your parent or legal guardian), via email or within the Service.
9 | HOW TO CONTACT US
If you have any questions about this Privacy Policy or our security measures at DopaGE, or where applicable to appeal a decision we’ve made regarding your privacy rights, please contact us at hello@dopa.ge. Our mailing address is 108 Lakeland Ave, Dover, DE 19901.
Request to Remove or Update Data
If learners or parents want to request the deletion of their student’s data, you can send us an email to request that we remove it by contacting us at hello@dopa.ge. If you would like to amend your profile information, you may log in to your account and do so or email us at hello@dopa.ge. You should understand that in some cases, we may retain copies of such information in our systems or databases where required or permitted by law.
Request to Opt-Out of Emails
Where we have permission, we may send periodic marketing emails to you. You may opt-out of such communications by following the opt-out instructions contained in the email or by contacting us at hello@dopa.ge. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other content we think may interest you, we will still send you service emails about your DopaGE account or any services you have requested or received from us.
DopaGE General Privacy Policy
Updated June 2, 2023