myLIBRO is committed to building a safe and trusted platform for our clients. This policy (“Privacy Policy”) is meant to help you understand our practices regarding the collection, use, and disclosure of personal information in connection with our websites, applications, programs, and/or software provided or made available by myLIBRO (the “Services”), as well as inform you of your rights and choices about the use of your information. We will not use, disclose, or share your information except as described in this Privacy Policy.

This Privacy Policy discloses the privacy practices for all myLIBRO-hosted websites, software, technologies, services, support services, applications including myLIBRO app, and myLIBRO accounts (collectively referred to as “Services”).

myLIBRO respects your privacy. The purpose of this Privacy Policy is to make you aware of how myLIBRO collects, manages, protects, uses, and/or shares information and what choices are available to you regarding the collection, use and distribution of your Personal Information and non-personally identifiable information (“non-PII”).

Many users under the age of 13 enjoy using the Services. To see myLIBRO’s policy regarding the collection of information from children who are under 13 years old, please refer to myLIBRO’s Privacy Policy for Children.

Is this the only policy governing the use of my information on services offered by the library?

No. Information you provide on the myLIBRO may be transmitted to your library and its designated service partners, where it will be handled according to the policies your library has implemented in those environments. Please check the library’s website to view these documents or speak to a librarian.

What Type of Information does myLIBRO Collect About Me?

User Personal Information

“Personal information” is information that reasonably allows us to identify you. We collect the information you voluntarily provide when registering to use our Services, filling in forms on our website, or contacting us by phone, email, chat, or social media. Also, when you interact with us through the Services, we collect the information you provide, usage information, and information about your device. Such information may include your name, email, and any other information you voluntarily share with us in such interactions.

• Personal Identifiers, including first and last name.
• Contact Information, including email address(es), and phone number(s) if provided.

We may collect non-public personal information about you from the following sources:

• Yourself
• Your Library

What is Personal Information and non-PII?

Generally, “Personal Information” is information that can be used on its own to identify a specific person. For example, Personal Information can be a full name, home address, email address, phone number, or login details. In most cases, non-personally identifiable information or “non-PII” is data that cannot be used on its own to identify a specific person.

Non-PII is treated by myLIBRO as Personal Information when it’s collected on an individual level and linked to any Personal Information that you have chosen to submit to myLIBRO or that myLIBRO may have collected from your interactions with the Services.

What information do I need to submit to myLIBRO to use the Services?

You can use most Services without submitting much information to myLIBRO. A valid library card is all you need to use most Services.

A myLIBRO account is not required to use most library Services. If you choose to create a myLIBRO account, you will be required to submit Personal Information to myLIBRO.

As part of your interaction with the Services, you may willingly submit your Personal Information to access certain features, such as submitting your email address to place a hold on a digital content title.

What information does myLIBRO gather?

In addition to information that you may willingly submit to myLIBRO, such as your library card number, pin number, and/or email address, myLIBRO may collect and store certain Personal Information and non-PII related to your interactions and use of our Services, including but not limited to device type, device ID, operating system, library card number, library name, pickup, and another in-library schedule history, feedback, notes.

Some Services provide the ability for you to see your lending history, holds, checked out items. However, we do not store this information on our servers.

Is my personal information protected?

myLIBRO takes information security very determinedly. We have implemented action to protect against the loss, misuse, and alteration of your information. Your information is protected by electronic, and procedural safeguards to prevent unauthorized disclosure. We have encrypted the transmission of information using secure sockets layer (SSL) technology. We use computer safeguards such as firewalls and data encryption it controls to our buildings and files. We authorize access to Personal Information only for those employees who require it to fulfill their job roles and responsibilities.

How does myLIBRO use my information?

We will use your personal information in connection with the reason for which it was provided, including to:

• Furnish or perform our Services, including preparing and filing required reporting to government agencies when required for registered Users, verifying your information or identity, or providing support related to our Services.
• Determine your current geographic location and/or language so that we may provide localized content and Services.
• Capture your voice to provide conversational interaction, only upon you invoking it explicitly. We do not listen continuously or automatically.
• Comply with the requirements of our publisher, library, and retail partners.
• Alert you of opportunities to renew loans, return loans, checkout digital content on which you’ve placed a hold, and cancel holds.
• Sync bookmarks and most recent point viewed/played across devices.
• Support the internal operations of the Services, including but not limited to support for: activities necessary to maintain or analyze the Services, network communications, user authentication or personalization of content, activities necessary to perform authorized school or educational purposes, and security of users;
• Personalize our Services to better reflect interests and preferences and
• Generally, improve your experience, including developing new features or services.

myLIBRO never sells your Personal Information or non-PII. myLIBRO will not use your information for any purposes other than the specified use.

Email addresses submitted to myLIBRO for holds notifications are stored by myLIBRO so you can place future holds in a swift, more user-friendly.

Device Identifiable Information

We may collect information about you that may not reasonably identify you or your household personally but instead is linked to your computer or device (“Device Identifiable Information”). We collect Device Identifiable Information from you in the normal course of providing the Services. For example, when you visit our website to browse, read, or download information, we utilize commonly used browser storage mechanisms and information-gathering tools.

• IP Addresses – When you visit our website, we may collect your Internet Protocol (“IP”) addresses to track and aggregate information for data analytics and for security and fraud tracking. Information related to your IP address may contain information about your domain provider, internet provider, and general geographic location. In addition, we may collect information about your mobile devices such as the type and model, operating system (e.g. iOS or Android), carrier name, mobile browser (e.g. Chrome, Safari), applications using our website, and identifiers assigned to your devices, such as its iOS Identifier for Advertising (IDFA), Android Advertising ID (AAID), or unique device identifier (a number is uniquely given to your device by your device manufacturer), sometimes referred to as a mobile carrier ID. We may also collect your location information, such as your zip code or the approximate geographic area provided by your Internet service provider (ISP) or location positioning information provided by the location services and GPS features of your mobile device when location services have been enabled.

How long is information retained by myLIBRO?

We retain information for as long as myLIBRO deems necessary to provide the Services or as otherwise permitted by applicable law. Information about schedule, statistics on usage of school Services is only retained by myLIBRO for the period necessary to support the authorized library or educational purposes.

Does myLIBRO use cookies and similar technologies?

Yes, we use cookies and similar technologies to collect and store certain information when you use, access, or interact with the Services. Cookies are small data file identifiers that are transferred to your device or web browser that allow us to recognize your device or web browser when you visit or use the Service. These files do not contain or transfer any personally identifiable information.

External Sites

The Internet is a big place: take care to guard your personally-identifying information. This website may link to other websites that collect personal information. We recommend that you review the privacy policies of these sites before providing them with any personal data.

What if I share information with others while using the Services?

While using our Services, you may enjoy opportunities to post reviews, with others in public forums and on social networking websites such as Facebook, Twitter, and Goodreads. When you share such information, it is made public and is not subject to this Privacy Policy. We are not responsible for any third party’s use of information you publicly display or disclose through our Services.

What happens when I visit an external website not related to myLIBRO’s Services?

myLIBRO is not responsible for the information handling practices of these other websites. These linked websites have separate and independent privacy statements, notices, and terms of use, which we recommend you read carefully.

Is my information transmitted to other countries?

The Internet is a global environment, using the Internet to collect and process information necessarily involves the transmission of data on an international basis. Therefore, by using our Services, you acknowledge and consent to the transfer of your information outside of your country to any country where we have facilities or engage third parties like (including but not limited to, cloud service or other Information Technology providers, and other companies that provide services to us). You understand that the countries which we may transfer information may not have as inclusive a level of data protection as in your country. myLIBRO requires that third parties (if any), such as cloud service providers, with whom information about users are obligated to safeguard such information using policies and procedures that are compatible with this Privacy Policy and must only use the information in order to perform the authorized school or educational purpose for which it was provided.

What if I contact myLIBRO for a support issue?

If you contact myLIBRO directly for assistance resolving an issue with the Services, it may be necessary for myLIBRO to resolve your issue.

What is required to create a myLIBRO account?

Library Name, Library Card Number, email address, and pin number/password are required to create a myLIBRO account. By creating and using a myLIBRO account and/or otherwise consenting to the sharing of information with us, you authorize myLIBRO to collect and retain the Personal Information submitted by you. You may not share your information regarding your myLIBRO account, including but not limited to your login credentials such as your password.

Rights applicable to users located in the EU

Legal basis for processing your Personal Information. If you are visiting a Service from the EU, we must have a legal basis to process your Personal Information. There are different legal bases on which we rely to process your Personal Information, namely:

Performance of a contract. The use of your Personal Information may be necessary to perform the specified function for which you submit your Personal Information, and/or perform other contractual obligations and policies under which we provide our Services to you.

Consent. We will rely on your consent to use your information for direct marketing purposes. You may withdraw your consent at any time by contacting us using the information at the end of this Privacy Policy.

Legitimate interests. We use your Personal Information for our legitimate interests to improve our Services, for internal administration, and for security purposes. In such circumstances, it is important for us to ensure that your data protection interests or fundamental rights and freedoms are not overridden by our legitimate interests.

Your choices under EU law. If you are visiting from the EU, you may email privacy@mylibro.com to ask us to:

• See what Personal Information we hold about you
• Modify or correct the Personal Information we hold about you
• Object to our use of your Personal Information
• Erase your Personal Information
• Receive/Port your Personal Information in a usable electronic format

If contacting us does not resolve your issue, you have the right to make a complaint to your data protection authority (if one exists in your country).

If you are not subject to EU law, these rights do not apply to you.

Rights applicable to California residents

As explained in this Privacy Policy, myLIBRO may collect certain information related to your interactions and use of our Services.

Information we collect directly from you. Depending on your use of the Services, the categories of information we may collect directly from you include the following:

• Identifiers, such as your name, email address, library card number, and phone number (only for users of IDP);

We may also collect the information you provide in your communications to us, such as when you respond to polls or surveys or contact us with a question, comment, or request.

Information we automatically collect from you. As you interact with the Services, we may also collect information about you automatically through the use of cookies and similar technologies. Depending on your use of the Services, the categories of information we automatically collect from you may include the following:

• Identifiers, such as IP Address, Adobe ID, Cookie ID, and device ID.
• Internet or other electronic network activity information, such as device type, operating system, browsing history on myLIBRO-hosted webpages, and information related to your interaction with the Services, such as lending history, holds and reading progress.

If you do not want myLIBRO-hosted websites to collect information using cookies, you can set your web browser to block cookies.

Information selling, sharing, and disclosing. myLIBRO does not sell your information. myLIBRO does not share your information with third parties for money or other valuable consideration. myLIBRO may disclose your information to service providers solely for business purposes. myLIBRO providing you access to the Services, and assist myLIBRO in monitoring, analyzing, and optimizing the Services. The following categories of information may be disclosed to service providers for business purposes: identifiers and internet or other electronic network activity information.

Your rights under applicable law. If you are a California resident, you or your authorized agent may email privacy@mylibro.com, to ask us to:

• See what Personal Information we hold about you
• Modify or correct the Personal Information we hold about you
• Delete your Personal Information
• Receive/Port your Personal Information in a usable electronic format

Users may freely exercise these rights without fear of being denied the Services.

Changes to this Privacy Policy

This Privacy Policy was last updated in July 2020. We will continue to evaluate this Privacy Policy against new technologies, business practices, and our users’ needs, and may make changes to the Privacy Policy accordingly. Your continued use of the Services after the posting of any changes to this Privacy Policy means that you agree to be bound by such changes. Please check the Privacy Policy periodically for updates.

In the event of a change of control (i.e. sale of company or merger of ConverSight, Inc.) the successor entity will be subject to these same privacy commitments.

If we make material changes this Privacy Policy that increases our rights to use your Personal Information, we will notify you via prominent notice on the Services or via email prior to the change becoming effective. If you do not agree to the changes, you should discontinue use of the Services.

What are my Rights to My Information?

All Users: Choices and Controls

You have various choices with respect to the collection of and certain of our uses of the personal information we collect from you on or through the website or Services. If you have not consented to us using your personal information as described in this Privacy Policy, we will only use it to complete the transaction or provide the service or product you have requested.

If you want to access, review, update, or correct inaccuracies in your personal information, or delete your personal information, you can:

Please contact myLIBRO at privacy@mylibro.com if:

• You have any questions about this Privacy Policy.
• You are not located in the EU or are not a California resident and you would like to request access to the Personal Information we hold about you or request the deletion of your Personal Information.
• You are a parent and want to inquire if your child has submitted Personal Information to myLIBRO and to request the review, correction, and/or removal of any such Personal Information from our system; or You are a teacher or administrator at an educational institution using the school Services and want to request the review, correction, and/or removal of a student’s Personal Information.