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Privacy Policy

These privacy policies were last modified January 28, 2020.

Pennington Publishing ("us", "we", or "our") operates the website (the "Service") as well as browser applications (the “Application”)

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and/or Application and the choices you have associated with that data.

We use your data to provide and improve the Service and/or Application. By using the Service and/or Application, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from


  • Service

Service is the website operated by Pennington Publishing

  • Application

Application is any of the web browser extensions published by Pennington Publishing

  • Personal Data

Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

  • Usage Data

Usage Data is data collected automatically either generated by the use of the Service and/or Application or from the Service and/or Application infrastructure itself (for example, the duration of a page visit or the length of time using the Application).

  • Cookies

Cookies are small pieces of data stored on your device (computer or mobile device).

  • Data Controller

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.

For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

  • Data Processors (or Service Providers)

Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.

We may use the services of various Service Providers in order to process your data more effectively.

  • Data Subject (or User)

Data Subject is any living individual who is using our Service and/or Application and is the subject of Personal Data.

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service and Application to you.

Types of Data Collected

Personal Data

While using our Service and/or Application, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Address, State, Province, ZIP/Postal code, City
  • Cookies and Usage Data

We may use your Personal Data to contact you with email newsletters, email marketing or promotional emailed materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

Usage Data

We may also collect information how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the usage of certain functions of the Application, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. None of this data is shared with third-party sources. Usage data is only used for internal purposes.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and Application and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.

No tracking cookies are used for advertising purposes or for affiliate programs.

Use of Data

Pennington Publishing uses the collected data for various purposes:

  • To provide and maintain our Service and Application
  • To notify you about changes to our Service or Application
  • To allow you to participate in interactive features of our Service or Application when you choose to do so
  • To provide customer support
  • To gather analysis or valuable information so that we can improve our Service
  • To monitor the usage of our Service and Application
  • To detect, prevent and address technical issues
  • To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or inquired about unless you have opted not to receive such information

None of this data is shared with third-party sources. None is used for commercial purposes beyond the applications listed in the above session.

Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), Pennington Publishing legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

Pennington Publishing may process your Personal Data because:

  • We need to perform a contract with you
  • You have given us permission to do so
  • The processing is in our legitimate interests and it's not overridden by your rights
  • For payment processing purposes
  • To comply with the law

Retention of Data

Pennington Publishing will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Pennington Publishing will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service and/or Application, or we are legally obligated to retain this data for longer time periods.

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — secure computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Pennington Publishing will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data

Business Transaction

If Pennington Publishing is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement

Under certain circumstances, Pennington Publishing may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

Pennington Publishing may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of Pennington Publishing
  • To prevent or investigate possible wrongdoing in connection with the Service and/or Application
  • To protect the personal safety of users of the Service and/or Application or the public
  • To protect against legal liability

Security of Data

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

"Do Not Track" Signals

We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Pennington Publishing aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

  • The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your Personal Data.
  • The right of restriction. You have the right to request that we restrict the processing of your personal information.
  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where Pennington Publishing relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Service Providers

We may employ third party companies and individuals to facilitate our Service and Application ("Service Providers"), to provide the Service and/or Application on our behalf, to perform Service-related services or to assist us in analyzing how our Service and/or Application is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.


We may use third-party Service Providers to monitor and analyze the use of our Service.

  • Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page:

Behavioral Remarketing

Pennington Publishing uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service.

  • Google Chrome Web Store

Google Chrome Web Store is an application store for the Chrome web browser provided by Google, Inc

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page:


We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

  • PayPal or Braintree

Their Privacy Policy can be viewed at

  • Shopify

Their Privacy Policy can be viewed at

  • Google Payments

Their Privacy Policy can be viewed at

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

e-Comments Chrome Extension Privacy

The following section covers limitations and specific 
application of the above policies regarding Pennington
Publishing's e-Comments Chrome Extension.

The e-Comments Chrome Extension uses Google Sign-In and Google
Drive purely for the purpose of allowing the user to save and
sync comment data between devices that they are logged into.
Only the user has access to this data, except for comment data
which the user chooses to share. Pennington Publishing has no
access to personally-identifiable data shared in any
Google apps by means of the e-Comments Chrome extension; thus,
no data is shared for commercial purposes.

Use of the e-Comments Chrome Extension by Children
The e-Comments Chrome Extension does not facilitate the 
transmission or storage of data on any device other than the
user's personal devices and Google Drive account, except when
the user chooses to post comments on a shared Google Doc or
Slide file.
Teachers, parents, and legal guardians assume full 
responsibility and complete liability for monitoring
Children's use of the e-Comments Chrome extension and the
data children share via the Google apps or by any other means
of transmission. Pennington Publishing has no access
to the personally-identifiable data of children nor adults.
thus, no data is examined, nor shared for commercial purposes.
When using a license for multiple users, also known as a group 
license, only the single license holder who purchased the
e-Comments Chrome Extension or authorized designee shares email
contact information with Pennington Publishing to activate the
license. The purchaser or designee activates the users'
accounts via their respective emails. Pennington Publishing
has no access to user emails.

Incident Response Policy Pennington Publishing

Policy Owner

Mark Pennington

Policy Approver(s)

Mark Pennington

Storage Location

Effective Date


Next Review Date




The purpose of this policy is to ensure that Pennington Publishing’s incident response capabilities, used to monitor for security incidents have a maintained quality and integrity. The incident response capabilities determine the magnitude of the threat presented by these incidents, and to respond to these incidents. Without an incident response capability, the potential exists that in the event that a security incident occurs, it will go unnoticed and the magnitude of harm associated with the incident will be significantly greater than if the incident were noted and corrected.


The Incident Response Policy applies to all information systems and information system components of Pennington Publishing. Specifically, it includes:

  • Mainframes, servers, and other devices that provide centralized computing capabilities.
  • SAN, NAS, and other devices that provide centralized storage capabilities.
  • Desktops, laptops, and other devices that provide distributed computing capabilities.
  • Routers, switches, and other devices that provide network capabilities.
  • Firewalls, IDP sensors, and other devices that provide dedicated security capabilities.

Governing Laws & Regulations

If applicable, list any laws or regulations that govern the policy or with which the policy must comply. Confirm with the legal department that the list is full and accurate. If there are no pertinent governing laws or regulations, delete this section.



NIST SP 800-171



Policy Statements

Basic Security Requirements:

  • An operational incident-handling capability will be developed and implemented for all organizational information systems that house or access Pennington Publishing controlled information. The incident response capability will include a defined plan and will address the seven stages of incident response:
    • Preparation
    • Detection
    • Analysis
    • Containment
    • Eradication
    • Recovery
    • Post-Incident Activity
  • Incidents will be tracked, documented, and reported to appropriate officials and/or authorities both internal and external to the organization.

Derived Security Requirements:

  • Incident response capabilities will be tested quarterly.
  • To facilitate incident response operations, responsibility for incident-handling operations will be assigned to an incident response team.
  • Incident response plans will be reviewed and, where applicable, revised on an annual basis. Review will be based on the documented results of previously conducted tests or live executions of the incident response plan. Upon completion of plan revision, updated plans will be distributed to key stakeholders.


Clearly describe consequences (legal and/or disciplinary) for employee non-compliance with the policy. It may be pertinent to describe the escalation process for repeated non-compliance.

Violations of this policy will be treated like other allegations of wrongdoing at Pennington Publishing . Allegations of misconduct will be adjudicated according to established procedures. Sanctions for non-compliance may include, but are not limited to, one or more of the following:

  1. Disciplinary action according to applicable Pennington Publishing policies
  2. Termination of employment
  3. Legal action according to applicable laws and contractual agreements

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions or comments about these policies, please e-mail our Data Privacy Officer at

You can also write to us at:

ATTN: Data Privacy Officer
Pennington Publishing
3716 Falkirk Court
El Dorado Hills, CA 95762