MIS / Technology - Levy County School District

Rule 6A-1.0955, Florida Administrative Code - Online Educational Service Personally Identifiable Information Disclosures

Online Educational Service	PII Collected	How PII Is Destroyed	Terms of PII Redisclosure	Link(s) to Terms of Service and/or Privacy Policy
Achieve 3000	We only collect the information required to provide, maintain and improve the digital learning solution you use. When you register, or are registered within one of our digital learning solutions, we collect your name, school, instructor, class, and login information. Once you begin using one of our solutions, we collect your input to questions, technical specifications, and other information about how you use the solution. You are not required to provide PII; however, in order to use certain services, we may need to collect certain PII for that service to function properly or for us to provide you with requested information. Depending on the product, the PII we collect includes information from the following categories: Name, initials, and personal or business-related contact information For our digital learning systems, we collect your name/initials and contact information when you create an account. However, we collect additional PII, or confirm existing PII, if you contact customer service with an issue or question. Education & professional information For some digital learning systems, we collect PII related to your position as an educator or student. This includes the state, district, name of school, courses, etc. In some instances, we collect PII from third parties who provide single-sign-on functions via Learning Management Systems or related tools. We automatically collect computer metadata and content to provide, improve, and maintain our products and services. When you use our digital learning systems, we automatically collect certain information from you through the use of cookies, web beacons or other tracking mechanisms. This includes information about your experience such as your IP address, operating systems, pages viewed, and time spent. Third parties also collect information automatically from you across websites and over time through the use of their own cookies, web beacons, and tracking mechanisms. This information is used to enable the functions of the digital learning system, as well as customize, maintain, and improve our digital learning systems. You may disable cookies via your browser or third party mechanisms. However, some features of our digital learning systems may not function properly without them. Third party cookies that we use include Google Analytics and Webtrends. If you choose to communicate with or receive communications through our services via phone, text, chat, email, or any other platform for technical support, customer service, or other assistance, those interactions may be recorded and monitored to deliver the solution or information requested by you.	We will retain your data for the minimum amount of time necessary to accomplish the purpose for which it was collected, and thereafter no longer than is permitted under McGraw Hill’s data retention policies. We will retain and use your data as necessary to comply with our obligations, resolve disputes and enforce agreements. For information on the retention period that applies, reach out to the Privacy Office by emailing privacy@mheducation.com or calling +1-646-766-3199.	In general, we only share your PII in order to provide, maintain, or improve our products or services, or respond to legal requests. Co-branded/Other Web Sites and Features – We may share your PII with third-party business partners for the purpose of providing the service to you. These third-party business partners include cloud service providers, learning management systems (LMS), other educational software providers, etc. These business partners will be given limited access to the PII that is reasonably necessary to deliver the service, and we will require that such third parties follow the same privacy and security practices as McGraw Hill. Business Transfer – In the event of a sale, merger or acquisition, we will be able to transfer your PII to a separate entity. We will require this entity to use your PII only for authorized purposes and by authorized persons in a manner consistent with the choices end users have made under this notice, and that security, integrity, and privacy of your PII is maintained. Agents/Service providers – We hire other companies to perform certain business-related functions on our behalf and according to our instructions. For example, we provide your PII to service providers that host our platform data in the cloud (e.g., AWS). Affiliates – McGraw Hill is a global corporation that consists of multiple organizations. We share your PII between organizations within McGraw Hill to provide, maintain, and improve our products and services. A list of the companies within the McGraw Hill group is available here. Educational Institutions / Corporation – As we provide products and services to your institution / corporation, we share your data with approved individuals such as administrators or educators. Law Enforcement – In the event that McGraw Hill receives a legal demand for end user data from a law enforcement agency, that request will only be honored if: The request complies with all laws and clearly establishes the legal need for disclosure. The request is related to a specific investigation and specific user accounts are implicated in that investigation. Whenever legally permissible, users shall receive notice that their information is being requested. McGraw Hill reserves the right to disclose to third parties non-personally identifiable information about our users and their use of the McGraw Hill services. For example, McGraw Hill may disclose aggregate data about the overall patterns or demographics of the users of the McGraw Hill products or services.	Terms of Service Privacy Policy
AEST	Depending on the Services, we may collect the following data in order to manage day to day business needs including, but not limited to, providing you with our services, performing services on behalf of a business, payment processing and financial account management, business planning and forecasting, system improvements, security and fraud prevention, and compliance with legal and regulatory obligations: Identifiers such as a real name, postal address, unique personal identifiers, Internet Protocol (IP) address, account name, email address, or other similar identifiers Geolocation data Professional or employment-related information Education information	We will continue to process your data until you delete your account or until this network is no longer active. If AEST, Inc. also acts as a Data Controller, we will keep your data until all the networks provided by AEST, Inc. that you are a member of are no longer active or until you delete your account. AEST has implemented policies and procedures to erase or otherwise destroy personal information collected once the information is identified for destruction.	We use Personal Data to provide services and information, to administer testing programs, to administer testing programs on behalf of your credentialing agency, and for our legitimate purposes in operating our business. Examples of our use or disclosure of your Personal Data include, but is not limited to: Providing test delivery services to you, including test scheduling and administration, maintaining the integrity of the testing process, and score reporting as directed by your credentialing agency. Providing candidates further information about certification, credentialing, and employment. Our legitimate business purposes as needed to manage day to day business needs including, but not limited to, performing services on behalf of a business, payment processing and financial account management, business planning and forecasting, security and fraud prevention, and compliance with legal and regulatory obligations.	Terms of Service Privacy Policy
Beanstack	Students using Beanstack through a single-sign on connection are not able to enter personally identifiable information. If we learn that a child under the age of 13 has submitted personal information online without parental consent, we will take all reasonable measures to delete such information from our databases and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required or allowed by law). If you become aware of any personal information we have collected from children under age 13 without parental consent, please contact us using the information detailed in the Contacting us section below. We take our role as stewards of Student Personal Data very seriously. We collect and use Student Personal Data only as necessary to provide the applicable school-related Services. WE DO NOT (a) sell or monetize Student Personal Data; (b) display advertising to students on the school-related Services; or (c) authorize behavioral tracking by third parties on the school-related Services for the purpose of targeted advertising or to show ads on such Services.	Personal information that we collect, access or process will be retained only as long as reasonably necessary for the fulfilment of the purposes for which it was collected, unless otherwise provided for under services contracts with clients or as required or authorized by law. Personal information that is no longer required to fulfil the identified purposes will be destroyed, erased or de-identified.	Our clients (e.g., schools and libraries) are responsible for notification of purpose and for obtaining appropriate consent, to the extent required by law, when they collect personal information that is transferred to us. If we are instructed by our clients to transmit communications on their behalf, clients remain responsible for ensuring that recipients have consented to receiving such communications and that the information contained in the communications are accurate and complete. We do not sell, rent, or share the personal information of our users with third parties for such third parties' own marketing purposes. We may, subject to applicable laws, use personal information from our users to contact them about the Site and Services, including to provide them with information on additional products from us that may be of interest to them. Our users may exercise choices regarding these communications as follows: Mail marketing, Telephone marketing, Surveys and Quality control communications (as applicable). You may decide that you prefer that we not use your personal information to promote new and/or additional products and/or services which may be of interest to you and refuse that we contact you by mail or telephone for marketing purposes or by email or telephone for quality control purposes. If this is the case, you may advise us by contacting customer service or contacting us using the information detailed in the Contacting us section below. For clarity, we will not use any students' personal information that we receive from or in connection with a school (collectively, “Student Personal Data”) for marketing-related communications. For more information about Student Personal Data, see section 8 below. Emails/Commercial Electronic Communications. You can always limit the communications that we send to you. To opt-out of commercial emails, simply click the link labeled “unsubscribe” or “opt-out” at the bottom of any commercial electronic communication we send you. For clarity, students are automatically opted out of commercial electronic communications that do not specifically relate to the provision or support of the Services in which such students participate. Please note that even if you opt-out of promotional communications, we may still need to contact you with important information about your account.	Terms of Service Privacy Policy
Benchmark Education, LLC	We may request and store certain types of personally identifying information about you when you use our Sites, depending on how you interact with the Sites. We consider the following to be examples of personally identifying information: your first and last name, email address, home address, phone number, date of birth, social security number, student identification number, credit card and banking information, and other similar information. We do not collect personally identifying information about you unless it is voluntarily provided and needed for the delivery of services you wish to use. It is your choice whether to share personally identifying information with us but please keep in mind that in some instances such information will be required in order to participate in activities within the Sites. Please note that we DO NOT consider anonymized or aggregated information to be personally identifying information.We may also collect any comments, feedback, posts and other content you provide to us; any communication preferences; purchase and search history; and location-aware services, including the physical location of your device in order to provide you with more relevant content for your location.	We will not keep personal information longer than is necessary for the purpose for which it was collected. Unless information must be retained for legal or archival purposes, personal information will be securely destroyed, put beyond use or erased from our systems when it is no longer required or, where applicable, following a request from you to destroy or erase your personal information.	We will not share or disclose your personal information with any unaffiliated third party, except: (1) when the third party is an academic institution, employer, or other entity that has provided you with access to the Sites or any of our products or services; (2) if you participate in a program in which we have partnered with a third-party; (3) if the disclosure is necessary to maintain the security and integrity of the Sites or to protect the users of the Sites, consistent with applicable law; (4) when sharing the information is necessary to improve the Sites, our product, services, technology, content, or similar functions provided that the third party has committed to protecting the privacy of personally identifiable information in a manner consistent with this Privacy Policy; (5) when required by law or regulation, including in response to subpoenas; (6) in the event of a sale of some or all assets or business of Benchmark to a third party; (7) to process any transactions you request (such as providing a credit card processor with your information to process the transaction); (8) to enforce the Terms of Use; and (9) where you have consented to the disclosure. When you conduct a purchase transaction through the Sites, you are providing transaction information to our third-party suppliers (such as transaction processors and financial institutions) who will use the information solely for processing your requested transaction. There may also be other third-party vendors who supply software applications, web hosting and other technologies and/or services for the Sites that may have access to your personally identifying information but, unless they get express permission from you, they will not use such information for any other purpose other than to provide services in connection with this Sites.	Terms of Service Privacy Policy
Big Ideas	Personal Information: We collect personal and contact information you choose to provide to us in connection with your activities on the site (for example, name and contact information, school, login credentials, book orders). What we collect depends on whether you register through Clever or on our site directly. In either case, if you are a minor, your school has acted as your parent or guardian’s agent and has consented to this collection on your behalf. If you are under 13 years old, this consent fulfills our obligation under the Children’s Online Privacy Protection Act. Our collection of personal information to set up your account is in furtherance of our performance of services otherwise performed by school employees, is under the direct control of the school with respect to the use and maintenance of educational records, and complies with use and redisclosure requirements regarding personal information from education records, all in compliance with the Family Educational Rights and Privacy Act. Registration through Clever: Schools may register their students for bigideasmath.com through Clever, a third-party service providing single login functionality for a variety of educational applications. Schools will provide Clever with the following information for each teacher and student: First and last name School name and school address Individual’s school email address Schools may opt to share additional student information with Clever, such as gender or date of birth. Your personal information is stored and encrypted by Clever, not by us, but we are able to view this information. Information you provide to Clever directly is governed by its privacy policy, which you can find here: https://clever.com/about/privacy-policy. Clever has agreed to adhere to the Student Privacy Pledge. Registration by Teacher: A teacher may choose to register directly through our site. The district will provide each teacher with a link and a district or school- level access code so the teacher can set up an account. The teacher will provide us with the following information: Teacher’s first and last name School name and school address Teacher’s school email address. The teacher will provide each student in the registered class with a link and access code so the student can set up an account. The student will provide us with the following information: First and last name The teacher and student will also set up passwords. Other user information we collect: In addition, for each visitor to our site, we automatically gather certain other potentially identifying information and store it in log files. This information includes (as applicable) date/time stamp, student answers to questions, scores, access to assignments, live chat transcripts, and time spent on assessments. We collect and store this information on an individual basis and in aggregate, or combined, form. We use proprietary algorithms to calculate behavior, knowledge, and skill statistics using individual simulation activity for each student. “Do Not Track” Signals. We do not currently have the capability to recognize browser “Do Not Track” signals. We adhere to the standards set forth in this privacy policy. Cookies- A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. If you reject cookies, you may still use our site, but your ability to use some areas of our site will be limited. We use secure session cookies to make it easier for you to navigate our site. We use session cookies to record session information, such as which web pages a user has visited, and to track user activity on the site. We also use session cookies to store any passwords used on the site (such as a password associated with a user account), so you don’t have to enter it more than once per session. These cookies are deleted when you close your web browser. Analytics- To determine how many users visit our site, how often they visit this site, and to better understand the areas of greatest interest to our visitors, we use a tools called “Google Analytics” to compile this information for us. As a result of your visit to our site, Google may collect information such as your domain type, your IP address and clickstream information. We do not combine the information collected through the use of analytics tools with personally identifiable information. For more information about the analytics companies’ ability to use and share information about your visits to this site, see http://www.google.com/intl/en/policies/privacy/. Advertising- We do not use third-party ad networks, targeted advertising, or display ads on this site.	We will retain your personal information in accordance with our continuing business need to support user services and fulfill our contractual obligations to educational institutions, and as may be required by law. At the completion of any contract, we will destroy personal information in our possession collected and maintained in connection with that contract within a reasonable time.	We store and process your Personal Information to authenticate your user’s license and to grant you access to the applicable materials. We also use information we collect to analyze trends, to administer the site, and to track users’ movements around the site. We also use this information to improve the site and to make it more useful to visitors. We do not share Personal Information we collect on this site with any third parties, except that (i) we may share student assessment results (grades and the like) with Clever if the school has registered through that third party service, and (ii) we may share Personal Information where we have a good faith belief that such action is necessary to comply with a current judicial proceeding, court order, or legal process. It is possible that, at some time in the future, our company may be sold along with its assets, or may engage in business transactions in which customer information is one of the assets transferred. In such a case, the customer information which we have gathered may be one of the business assets we transfer. Should such transfer occur, we will ensure that the successor entity agrees to act in accordance with Student Pledge principles or delete the information.	Terms of Service Privacy Policy
Blooket	nformation You Provide to Us There are currently two categories of users on our Service: users and visitors. We collect and store the following types of information from each type of user: Account Sign-up and Profile Information: To create an Blooket account, you may be asked to provide some basic information. If you create an Blooket account as a user, you will be asked to enter your first name, last name, username, password and email. Visitors who participate in games will be asked only for a username. Contact Information: When you choose to provide us with your personal information through the Service in some other manner (e.g., when you request a quote for upgrading to a "Blooket Plus", when you submit a copyright claim or report any media on our platform, when you send us an email asking a question, or submit a support request). Billing Information: When subscribing to any of our "Blooket Plus" options, you will be asked to provide necessary information for processing the payment (e.g., credit/debit card number). As further explained in the Security Measures section of this Privacy Policy, payments are processed over Stripe through their third party website service. Information Collected Automatically Like most web-based services, we (or our service providers) may automatically receive and log information on our server logs from your browser or your device when you use the Service. For example, this could include the frequency and duration of your visits to Blooket. If you use Blooket on different devices, we may link the information we collect from those different devices to help us provide a consistent Service across your different devices. If we do combine any automatically-collected information with personal information, we will treat the combined information as personal information, and it will be protected as per this Privacy Policy. The technologies and information we automatically collect include: Cookies and Other Similar Technologies: We (or our service providers) may use various technologies to collect and store information when you visit our Service, including clear GIFs (also known as “web beacons”), “tags”, “scripts”, and “cookies”. We also make use of persistent secure cookies: persistent cookie remains after you close your browser (although they can be removed) and may be used by your browser to identify you on subsequent visits to the Service. We may also use, collect and store information locally on your device using mechanisms such as browser web storage (including HTML 5). Like many services, Blooket uses these technologies to tailor the Service for you, and to help the Service work better for you - for example, by remembering your language preferences. Device Information: We collect, through our third-party analytics services, device-specific information such as your operating system, hardware version, device settings, file and software names and types, battery and signal strength, and device identifiers. This helps us measure how the Service is performing, and improve Blooket for you on your particular device. Log Information: Like most online services, when you use our Service, we automatically collect and store certain information in our server logs. Examples include: Details of how you used our service, such as your activity on the Service, and the frequency and duration of your visits to the Blooket Website. IP Address. Device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL. This information helps us make decisions about what we should work on next - for example, by showing which features are most (or least!) popular. Location Information: When you use our Service we may collect and process information about your geographic location, for example through GPS, Bluetooth, or Wi-Fi signals. We collect coarse (i.e., city-level) location data. We will not store or track your device location on an ongoing basis or without your permission. We do not share precise geolocation data with third parties, other than our service providers as necessary to provide the Service. Automated Decision Making and Profiling Automated Decision Making (ADM) refers to a decision which is taken solely on the basis of automated processing of your personal data. This means processing using, for example, software code or an algorithm, which does not require human intervention. Profiling means using automated processes without human intervention (such as computer programs) to analyze your personal information in order to evaluate your behavior or to predict things about you which are relevant in the context of using Blooket, such as what kind of games or Blooket sets you utilized. As profiling uses automated processing, it is sometimes connected with automated decision-making. Not all profiling results in automated decision-making, but it can.	We store your personal information for as long as it is necessary to provide products and Services to you and others, including those described above pursuant to our Data Retention Policy. Deletion will affect any on-going paid subscriptions, which will be immediately cancelled. Note we may retain and use de-identified data (i.e., data which has been stripped off all information that can be used to identify a person) for purposes of research, improvement of our products and services, and/or the development of new products and services. We may also have to retain some information after your account is deleted, to comply with legal obligations, to protect the safety and security of our community or our Service, or to prevent abuse of our Terms. In case we keep copies or backups of personal information, such copies or backups will be kept for a maximum term of eighteen (18) months after the deletion of your account.	Blooket's Third-Party Service Providers It is important to us that we keep your information safe and secure. To best provide our services, and keep your information safe, we work with a few other companies (we can't do it all ourselves!). These companies ("third-party service providers", "collaborators" or "agents") will only have access to the information they need to provide the Blooket service. Below is a list of the service providers which, subject to their terms of service and privacy policies, may have access to personal data to process on our behalf in accordance with our instructions, Privacy Policy and any other requirements regarding confidentiality, security or integrity: Amazon Web Services (AWS) for hosting Blooket's servers, videos, images and audios. Google Services for cloud storage, hosting Blooket's servers, analytics on our website ("Google Analytics"), and for spam and abuse protection ("reCAPTCHA"). Cloudinary for creating, managing and delivering images and audio across any browser. Sendgrid and Mailjet for email messaging. Mongodb is a general purpose, document-based, distributed database built for modern application developers and for the cloud era. Stripe as a payment processing service. This list may change over time, and we will work hard to keep it up-to-date. Blooket reserves the right to change or add service providers which provide services in concert with the provisions of this agreement. Accountability for Onward Transfer We will transfer your personal information to third-party service providers only for limited and specific purposes. We will obtain contractual assurances from our collaborators that they will safeguard personal information in a manner consistent with this Policy and that they will provide the same level of protection as per best industry standards. We recognize our responsibility and potential liability for onward transfers to agents. Where we have knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy and/or level of protection as required by applicable laws and regulations, we will take reasonable steps to prevent, remediate or stop such use or disclosure. If we transfer personal information to non-agent third parties, that is to say, any new collaborators that are not included in the previously mentioned list, we will (1) notify you with all necessary information on any key elements affecting the processing of your personal data, and (2) obtain contractual assurance from these parties that they will provide the same level of security as per best industry standards and in accordance with any applicable laws and regulations.	Terms of Service Privacy Policy
Branching Minds	Platform Data We Collect When our Districts create an account for their users, certain information about teachers, students, and other users is electronically synced from the District’s information systems to the Platform. This information may include: Log-in information; First and last name; E-mail address; School and District name; Student grade level; Student language proficiency; Student IEP status; Student date of birth; and Student ethnicity. Depending on the features offered by the Platform, users may have the ability to provide additional information and content, including posts, communications, profile information, assessment scores, and survey responses, as well as to upload documents and files. We do not collect geolocation, biometric, or health data. We and our service providers use cookies and other tracking technologies to automatically receive and record information on our server logs from a user’s browser or device, which may include: IP address; Cookie information; Type of browser and/or device used to access the Platform; and Pages or features the user requests. Users may be able to change the preferences on their browser or device to prevent or limit their device's acceptance of cookies, but this may prevent them from taking advantage of some Platform features.	We employ the United States Office of Education best practice recommendations for data destruction. Unless otherwise requested by the District LEA, all personal information provided to us will be destroyed upon termination of our relationship with the District (typically during September of the school year following the school year in which the District LEA opts to terminate our relationship), or when it is no longer needed for the purpose for which it was provided.	We do not sell any information we collect on the Platform, including student personal information, nor do we use or disclose any information we collect for (a) behavioral targeting of advertisements to students or (b) any other marketing purpose. We do not allow third-party advertising networks to collect information about Platform users. We do not facilitate the use or disclosure of any student personal information by any other party for any marketing purpose or permit another party to do so. We may share Platform data with our Districts (to the extent that data pertains to individuals associated with that customer), service providers that perform services on our behalf, authorities (for compliance and protection purposes), and participants in a corporate transaction with Branching Minds. We may also allow users to share information with other users where relevant to the features offered by the Platform. For example, we may permit users to interact and share information with each other in community forums and other interactive spaces. Lastly, we may share information as instructed by our Districts or their users. We do not sell any Platform data, nor do we make this information available for behavioral targeting of advertisements to students or any other marketing purpose.	Terms of Service Privacy Policy
Canvas	What Information Do We Collect About Children? How Information is Collected. We may collect information about Children directly from Children and/or their Schools, as well as automatically through a Child's use of our Services. We will not require a School or Child to disclose more information than is reasonably necessary to use our Services. Information We Collect Directly. We may collect a Child’s name and other personal information when a School provides it to us. For example, through our Services, Schools can create assessments and track their Students’ learning progress. In doing so, Schools may require the Child’s personal information in order to track and archive evidence of learning. Schools decide how they will use our Services and Schools are responsible for ensuring that their collection and use of personal information from Children through the Services complies with applicable laws. If you are a parent and you have questions about your Child's School’s use of our Services, you should discuss your questions with your Child’s School. Schools also have the option of creating accounts for their Students which allows those Students to view their learning progress and access learning resources provided by their School. If a School chooses to register a Child for an account, Canvas will generate a username and temporary password and provide them directly to the School which may then share them with the Child. After logging in, the Child can then create a permanent password for their account. Once an account is created, we collect information about Children’s performance and activities on our Services. We may use deidentified or aggregated data in order to improve our services. Parents can tell us to stop collecting personal information from their Children; however, in such cases the Children will not be able to use our Services. If you direct us to stop collecting and using your Child's personal information, we will notify the School of your request and disable your Child’s use of our Services. Information We Collect Automatically. We may automatically collect information about a Child’s use of our Services through our servers and in log files, such as the following: domain name; browser type and operating system; web pages viewed; links clicked; the length of time spent on our Services; the length of time our Services are used; the referring URL, or the webpage that led a user to our Site; language information; device name and model; operating system type, name, and version; and activities within our Services. We use this information to analyze trends, administer the Services, track users’ movements around the Services, gather demographic information about our user base, and better tailor our Services to our users’ needs. Except as noted in this COPPA Policy, we do not link this automatically collected data to a Child’s personal information. We may also collect IP address, device identifier or a similar unique identifier from Child users of our Services; we use such identifiers solely to support the internal operations of our Services in the same manner as described above, including to maintain or analyze their functioning; perform network communications; authenticate users or personalize content; and protect the security or integrity of users and our Services. We never use unique identifiers to track Child users across third-party apps or websites. We may also collect information from any mobile devices that a Child uses if the Child has downloaded one or more of our Apps to their device. This information is used to help us deliver the Services to the Child. Examples of information that may be collected and used include how the Child uses the App(s) and information about the type of device the Child is using. In addition, in the event our App(s) crash on a mobile device, we will receive information about the mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our App(s). This crash information is sent to us as aggregated information that does not identify an individual.	Parents and Schools have a right to review and correct the information we have collected about their Child(ren) and Students, respectively, and to delete it, and to tell us to update it or stop using it. To exercise these rights, you may contact us atprivacy@instructure.com. You will be required to authenticate yourself as the Child's parent or School to receive information about that Child. Please note that we cannot delete copies of information that a Child's School has already collected and/or copied, and copies of information that you have deleted may remain in archives for a period of time.	We do not sell personal information about Children, and there is no means for a Child to make his or her personal information public through our Services (though Schools may choose to share a Child’s information and responses with the Child’s classmates or with other teachers). We will disclose the personal information that we collect about Children only as follows: Parents, Teachers and Classmates. We will disclose Children’s personal information: (1) to each Child’s individual teacher(s) and parent(s); and (2) as directed by the Child’s School. Parents may request information about the information we have collected from their Child(ren) by contacting us atprivacy@instructure.com. Third-Party Service Providers. We may disclose a Child’s personal information to third-party service providers who perform functions on our behalf and/or on behalf of a School or district customer in order to: provide the Child and the Child’s School with the Services that we offer through our Services; conduct quality assurance testing; facilitate creation of accounts; provide technical support; and/or provide other services to us. These third-party service providers are permitted to use personal information only to provide the services requested by Instructure or the School or district customer. Business Transfers. If we are acquired by or merged with another company, if all or a portion of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the personal information we have collected about Children to the other company. We will notify all users of any material change in our information practices, as well as any choices users may have regarding their personal information. In Response to Legal Process. We may disclose personal information that we have collected from Children in order to comply with applicable law, a judicial proceeding, court order, or other legal process. To Protect Us and Others. We may disclose personal information that we have collected from Children 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, violations of our Terms of Service or our policies including this COPPA Policy, or as evidence in litigation in which Instructure is involved. Disclosure to Other Third Parties Only with Consent. Beyond the disclosures described in this COPPA Privacy Policy, Instructure will disclose a Child’s information to any other third party only at a School’s direction.	Terms of Service Privacy Policy
Cengage Learning	Personal Information is any information that can be used to identify, locate or contact you. It also includes information that can identify you when combined with other information. The Personal Information that we collect falls into the following categories and may differ based on how you interact with us: Contact Information that allows us to communicate with you, such as your name, mailing address, telephone numbers, email address or other addresses that allow us to send you messages. Identifiers that allow us to recognize you, such as a school ID, the account number that we assign you, username and password. Transaction Information about how you interact with Cengage, including information about your use of our content and information about how you use our websites and apps. Internet Network and Device Information that we collect about your session and your activity when you use our websites, apps and products. In addition to any information that you submit during these sessions, we use cookies and other technological tools to automatically collect information about your computer and your use of our websites and apps. The information we collect includes IP address; internet provider, operating system and browser used; domain names of the computers you use to visit our websites; viewed webpages; links that are clicked; the keystrokes typed; movement of the mouse or pointer; type of device (such as laptop or smart phone); device and advertising identifiers; log files; URIs (Uniform Resource Identifiers) of the resources requested; the time of the request; the method used to submit the request to the server; the size of the file obtained in reply; the numerical status code of the server reply (successful, error, etc.); emails we send that you open, forward or click through to our websites; and other parameters concerning your operating system and computer environment and/or device cookie settings and other device details, such as MAC address. Please see “Cookies and Other Data Collection Technologies” below for additional information. Other Voluntary Information includes Personal Information you provide us during your interactions with us (such as by sending an e-mail through our websites or by calling, e-mailing or writing to us). If you use our products and services, we also collect the following categories of Personal Information: Transaction Information about how you interact with Cengage, including your purchase and download history, information about your use of our content (including time spent on material and results of in-product assessments) and customer account information. We also collect payment card information as needed to process your payment when you purchase products from us. Audio Visual Information, such as photographs, video images or audio recordings that are captured when taking a course and call center recordings and call monitoring records that are made when you contact us for customer support. If you use our Cengage Academic products, for example, MindTap, WebAssign, Cengage Infuse, SAM, OpenNow, OWLv2 and Cengage Now, we also collect the following categories of Personal Information: Relationship Information that helps us do business with you. For students, this may include your school affiliation, expected degree and graduation date, your courses of study, grades, learning style, how you engage with our products, languages spoken, age range, how you interact with our content and others in your classes and similar information that can help us tailor our content and offer you personalized instruction. For professionals, this may include your professional credentials and affiliations and the products and services that may interest you or your school. If you are an instructor, we may also collect information about the types of courses you teach, your teaching style and student engagement and similar information that can help us tailor our content and improve your effectiveness in the classroom. If you use our Ed2Go or InfoSec products, we also collect the following categories of Personal Information: Relationship Information that helps us do business with you. This may include your employer, job title, professional credentials and affiliations, language spoken, age range and the products and services that may interest you. If you are an instructor, we may also collect information about the types of courses you teach, your teaching style and student engagement and similar information that can help us tailor our content and improve your effectiveness in the classroom. Military status. If you enroll in an InfoSec bootcamp, we also collect the following categories of Personal Information: Identifiers, such as your date of birth and income information. If you enroll in Externship thru Ed2Go, we also collect the following categories of Personal Information: Identifiers, including date of birth and license or passport. Resume Information, such as your work history, education history, course grades and certifications/licenses. Results of screenings, such as background check results (pass/fail) and drug screening results (pass/fail). Certain demographic information, only if you choose to provide this information. Sensitive Personal Information, such as limited vaccination information. In many cases, we collect Personal Information directly from you. We will ask you for Personal Information when you interact with us, such as when you register on our websites, signup to receive materials electronically or make a purchase. When you access our websites and apps, we automatically collect the information set out in “Internet Network and Device Information” above. We also collect the categories of Personal Information listed below from third parties: Business Contact Information for Gale Directory Products about corporate executives, academics and professionals. We obtain this information from third-party sources, such as company websites, publications, public record providers and other commercial sources. Please see “Gale Directory Products” below for more information. Relationship Information from your school, such as information about the classes you are teaching, or from third-party data suppliers who enhance our files and help us better understand our customers. Legal information from third-party providers, such as fraud checks or flags raised about your transactions, payment card refusals, suspected crimes, complaints and/or claims. Social Media Information if you interact with us through a social media service or log in using social media credentials. Depending on your social media settings, we may have access to your Personal Information from that social network such as your name, email address, age, gender and location. Contact Information about prospective customers from third-party lead providers.		We share your Personal Information, to the extent permitted by law, as follows: Within the Cengage group of companies. If you are affiliated with an educational institution, with your school and (if you are student) with your instructors. For example, we provide our institutional clients with reports about how their instructors and students use our products, including information that compares instructors and students within a school. If you are a student, your instructors will have access to the information generated by your use of the products for a class. We may also provide Personal Information to your school, as needed, to investigate possible academic fraud or cheating. Your school uses your Personal Information in accordance with its own privacy policies. With our service providers to the extent necessary to perform services on our behalf. With authorized partners that provide services to you through My Cengage, MindTap and similar platforms but only to the extent that you have authorized the sharing. For example, you may request that Cengage share information about the courses you’ve taken with partners to enable the partner to provide you with resume creation, skills assessments or other services. Additionally, we may share certain transactional information with our partners as needed to validate referrals and operate the platforms. With the company where you are doing an externship, if you are enrolled in Externship through Ed2Go. With your consent or at your direction. With other third parties, as permitted by law, to enforce our rights, including our Terms of Use or Terms of Service; to protect our property or to protect the rights, property or safety of others; and to detect, prevent and respond to fraud, illegal activity and intellectual property infringement. With law enforcement agencies, regulators and courts in the United States and other countries where we operate, such as in response to a subpoena or court order. With third parties in connection with, or as part of the due diligence for, any proposed or actual merger, acquisition, sale or transfer of some or all our assets (including in the event of a reorganization, dissolution or liquidation).	Terms of Service Privacy Policy
Chalktalk	We gather personally identifiable information when you contact ChalkTalk by mail, phone, e-mail, visit our site or fill out requests for information through our advertisements and promotions. We collect only personal information that you provide to us such as: name, address, phone number, e-mail address, grade level of student enrolling in courses and shipping and billing information for orders (i.e., credit card number and expiration date). We may also record the types of product information you have requested as well as technical information about your workstation or local area network.	At your request, at the end of the Term of this Agreement or if and when You otherwise require, We will return or destroy in a verifiable manner Student Data in our possession and provide You with copies of associated Program Data We have not previously provided to You. To comply with applicable laws, we reserve the right to destroy or otherwise dispose of Student Data and Program Data you have not directed us to return or destroy following this Agreement’s Term.	No personally identifiable information is shared with third parties unless you have provided personal information on behalf of your school, college, tutoring facility, or similar organization and have requested a trial or more detailed product information. In these cases, we will provide your contact information to our authorized sales representatives for your geographic area so that they can contact you and assist you with your sales related questions. We also provide your account manager with administrator access to help support your school with technical issues that may arise remotely without having to visit the school onsite for every small ticket. If you do not want us to disclose this information to our authorized sales representatives or technical support team, please write to us at: ChalkTalk Solutions, Inc., 281 Summer St, Fl 2. Boston, MA 02210 or e-mail us at info@chalktalk.academy with your full name in the subject line. Please be sure to include your first name, last name, address, city, state, zip code and phone number to ensure we can process your request. We will process your request promptly. Notwithstanding anything else in this policy, we may: (a) disclose personal and aggregate information when required by a valid legal mechanism such as a search warrant, subpoena, or court order, or when we deem it necessary to protect the safety of site users, our employees or property; and (b) disclose personal information in the context of the sale of some or all of our assets.	Terms of Service Privacy Policy
CI Solutions	When you visit, use, or navigate our Services, we may process personal information depending on how you interact with CI Solutions and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.	In Short: We aim to protect your personal information through a system of organizational and technical security measures. We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.	We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.	Terms of Service Privacy Policy
Classlink	ClassLink maintains data that can be categorized into two areas. Data related to customers and data related to our company. ClassLink maintains data needed for the operation of the ClassLink system. This data includes what is generally regarded as Directory Information such as name, school building affiliation, grade level, and email address. ClassLink may also maintain profile pictures, cell phone numbers for students age 13+ (to send password reset verification codes), student ID numbers, login credentials for various online resources, and personal computer files (temporarily cached for file transfers between cloud drives and stored until deleted by user for the ClassLink cloud drive). ClassLink does not generally maintain information such as mailing address, gender, date of birth, and other personal demographic data. We also maintain a variety of personal data about staff members needed for ClassLink human resources and payroll purposes. ClassLink is committed to ensuring that all Personally Identifiable Information (PII) entrusted to us is secure and that the privacy of both its customers and staff members is protected. Read more about our commitment to data privacy.		‍ClassLink is compliant with the regulations put forth by Fla. Stat. § 1002.22, Education records and reports of K-12 students; rights of parents and students; notification; penalty (§1002.22); and Fla. Stat. § 1002.222, Limitations on collection of information and disclosure of confidential and exempt student records (§1002.222). In addition to the above guiding principles on personal data: Biometric data of students, parents, and siblings: ClassLink does not collect biometric information as defined statute for students, parents, and siblings in Florida. Location: ClassLink contracts with educational agencies in Florida are governed by and construed in accordance with the laws of the State of Florida. Additionally, educational agencies in the United States are serviced by ClassLink servers and database infrastructure that are based in the United States.	Terms of Service Privacy Policy
Commonlit	1. Registration and Other Information You Provide The Services may collect "Personal Information" (which is information that can reasonably be used, alone or in combination with other reasonably available information, to identify or contact a specific individual). Personal Information includes, but is not limited to, student data, metadata, and user content. This may include a name, email address, username, password, or assessment results. Any information combined with Personal Information will be treated as Personal Information. 2. Your Account Page and Community Forums Your Account Page: Teachers must create an Account that contains the teacher’s name, password, email, role, and school. Students or teachers may create student accounts which contain their names, passwords, grade level, and may contain emails. Teachers cannot view students’ Account pages; however, teachers are able to view the name, email, and grade level of each of their students. Teachers may be able to view the name and email address of other teachers at their same school, but cannot view another teacher’s Account Page. Community Communications: The Services may provide teachers the opportunity to participate and post content that would be visible to other teachers, through interactive features and through other communication functionality ("Community Communications"). Note that anything you post to a Community Communication may be visible to others. 3. Third Party Services, Social Media Platforms, and Information Third Parties Provide About You Third parties may provide us with information about you. For example, if you are on a third party web site, and you opt-in to receive information from us, that third party will forward information about you to us so that we may contact you as requested. The Services may permit interactions between the Services and a third party web site or service, such as enabling you to "like" a product within our Services or "share" content to other web sites. If you choose to "like" or "share" content or to otherwise post information from or via the Services to a third party web site, feature or application, that information may be publicly displayed, and the third party web site may have access to information about you and your use of our Services. Similarly, if you publically post information on a third party platform that references CommonLit or one of the Services, your post may be published on our Services in accordance with terms of that third party. These features may collect your IP address or other Device Identifier, which page you are visiting on our web site, and may set a cookie to enable the third party feature to function properly. Third party features and applications are either hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the privacy policy(ies) of the company(ies) providing it. The information we collect is subject to this Privacy Policy. The information collected and stored by the third party remains subject to the third party's privacy practices, including whether the third party continues to share information with us, the types of information shared, and your choices with regard to what is visible to others on that third party web site and service. The third party may allow you to remove the application or feature, in which case we will no longer collect information about you through the application or feature, but we may retain the information previously collected in compliance with all applicable laws. Information We Collect Automatically Like other web sites and online services, we and our analytics providers, vendors and other third party service providers may automatically collect certain "Usage Information" whenever you access and use the Services. For example, we may collect information regarding when a user downloads resources such as pdfs or the pages a user accesses. Usage Information may include the browser and operating system you are using, the URL that referred you to our Services (if applicable), the search terms you entered into a search engine that lead you to our Services (if applicable), all of the areas within our Services that you visit (including information about any ads you may view), and the time of day you used the Services, among other information. We may use Usage Information for a variety of purposes, including to select appropriate content to display to you and to enhance or otherwise improve the Services and our products. In addition, we automatically collect your IP address or other unique identifier ("Device Identifier") for any computer, mobile phone or other device (any, a "Device") you may use to access the Services. A Device Identifier is a number that is automatically assigned to your Device used to access a Service, and our servers identify your Device by its Device Identifier. Some mobile service providers may also provide us or our third party service providers with information regarding the physical location of the Device used to access a Service, internet service provider (ISP), date and time of your visit, browser language, browser type, referring and exit pages and URLs, amount of time spent on particular pages, which parts of our Services you use, which links you click, search terms, operating system, traffic and related statistics, keywords, and/or other general browsing or usage data. Usage Information is generally non-identifying, but if we associate it with you as a specific and identifiable person, we treat it as Personal Information. Usage Information is collected via tracking technologies, including: 1. Cookies: Our Services utilize Cookies to improve your current and future experience by allowing us to understand your usage of our Services. For example, cookies help our systems recognize you if you return to our Services shortly after exiting them. Cookies are small text files stored on your computer that allow us to personalize the content of our Services. Cookies can be turned off via your browser settings if you so choose. However, if you turn your cookies off, some features of our Services may not function properly. 2. An Embedded Script: is programming code that is designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your computer or other device from our server or a third party service provider and is deactivated or deleted when you disconnect from the Services. In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes. 3. HTML5: We use Local Storage Objects (LSOs) such as HTML5 to store content, information and preferences. Third parties with whom we partner to provide certain features on our site use LSOs such as HTML 5 & Flash to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs. How We Respond To Do Not Track Signals: Please note that your browser setting may allow you to automatically transmit a "Do Not Track" (DNT) signal to websites and online service you visit. DNT is a privacy preference that users can set in certain web browsers to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. However, we do not recognize or respond to browser-initiated DNT signals, as the internet industry is still working to determine what DNT means, how to comply with DNT, and how to create a common approach to responding to DNT. To find out more about "Do Not Track", please visit http://www.allaboutdnt.com.	CommonLit takes data security very seriously. CommonLit takes commercially reasonable technical, physical, and administrative security measures designed to protect the Personal Information submitted to us, both during transmission and once we receive it. Such measures vary depending on the sensitivity of the information at issue. Measures taken to protect your data include: We continually test CommonLit’s security practices for vulnerabilities We periodically review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems We continually develop and implement features to keep your personal information safe - for example, all traffic to and from our application is over secure, encrypted protocols (SSL/TLS). We ensure passwords are stored securely using encryption and salted one-way hashing We also operate a ‘bug bounty’ security program to encourage an active community of third party security researchers to report any security bugs to us. More information on this is available by contacting us at security@commonlit.org. Every CommonLit employee participates in training on the importance of and methods for protecting Personal Information. Training consists of how to remain compliant with federal and state regulations (e.g . FERPA, COPPA, and SOPIPA), CommonLit policies, and general security posturing to protect student data (including techniques such as Two Factor Authentication, Drive Encryption, creating and managing strong passwords, etc). All CommonLit employees are trained in security practices and procedures designed to keep Your Data under strict internal controls. Developers peer-review code to make sure changes adhere to best practices for security. Administrators are knowledgeable of security practices and harden the infrastructure with necessary patches, monitor security resources for advisories and vulnerabilities, and scan the environment and application to ensure that student information remains secure. Please note that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially reasonable means to protect your Personal Information, we cannot guarantee its absolute security. How will CommonLit handle a data breach or security incident? In the event that CommonLit becomes aware of a data breach impacting your Personal Information, we will provide notification in compliance with all applicable laws. For example, we may post a notice on our homepage (www.CommonLit.org) or elsewhere on the Service, and may send email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. CommonLit has procedures in place that are designed to stop threats that may expose personally identifiable information, restore Services to full functionality, and document and take proactive steps to ensure the incident cannot be repeated. CommonLit will also preserve necessary evidence for investigation by security professionals and law enforcement as appropriate. In the unlikely event of an unauthorized disclosure of records, CommonLit will follow its internal procedures, which articulates how to report the problem to internal and external stakeholders. The notification process includes any information that can identify which customers and students may have been impacted, the data that may have been accessed, CommonLit’s process to inform affected customers, and steps to prevent the incident from happening again as appropriate. In the unlikely event of an unauthorized disclosure of Data, CommonLit has implemented a process for responding to incidents and notifying affected individuals and, if applicable, law enforcement personnel. If you have any questions about security on our Services, you can email us by clicking here.	CommonLit does not share your Personal Information with third parties for their marketing purposes in compliance with all applicable laws (including California Business & Professions Code section 22584 ("SOPIPA"), and California Education Code section 49073.1). CommonLit may share non-Personal Information, such as aggregate or de-identified user statistics, demographic information and Usage Information with third parties. We also may share your Personal Information with third parties with your consent (if permissible under applicable law), as disclosed at the time you provide us with information, and as described below or otherwise in this Privacy Policy: 1. Service Providers We will share your Personal Information with third parties to provide services to us or you in connection with the Services, but subject to confidentiality obligations which limit their use and disclosure of such information. For example, we may provide your Personal Information to companies that provide services to help us with our business activities, sending our emails, or offering customer service. If you purchase any merchandise, our billing partner will receive billing, shipping and financial information (e.g., credit card numbers) necessary to process your charges, including your postal and e-mail addresses, depending on your payment method. 2. Administrative, Legal Reasons & Academic Integrity Investigations We may also disclose your information, including Personal Information, in response to a subpoena, court order, or when otherwise required by law; in response to bankruptcy proceedings; to defend our rights; in response to a request from law enforcement; to provide information to a claimed owner of intellectual property who claims that content you have provided to us infringes on their rights; upon request of or as otherwise authorized by an academic institution connected to an investigation into academic integrity; to protect and/or defend any applicable Terms of Use or other policies applicable to the Services; or to protect the personal safety, rights, property or security of any organization or individual. We may also use Device Identifiers, including IP addresses, to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies in our discretion. These disclosures may be carried out without your consent or without notice to you. 3. Business Transitions CommonLit may share Personal Information with its parent, subsidiaries and affiliates, and investors primarily for business and operational purposes so long as any recipient agrees to comply with this Privacy Policy and applicable law with regard to such Personal Information. In the event that CommonLit goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, bankruptcy, or other corporate change, including, without limitation, during the course of any due diligence process, your information, including Personal Information, will likely be among the assets transferred. You will be notified via email and/or a prominent notice on Services of any completed change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information. This Privacy Policy will become binding upon the new owner of the information until amended. 4. Testimonials We display personal testimonials of satisfied adult users on our Services in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us via email by clicking here.	Terms of Service Privacy Policy
Curriculum Associates	CA receives certain information, which we receive pursuant to the school official exception under FERPA, from its school district customers to enable students to use i-Ready. The following information is generally provided to CA for each student user of i-Ready: • student first and last name; • date of birth; • gender; • ethnicity or race; • student identification number; • student school or class enrollment; • student grade level; • teacher name; • English language learner status, and; • eligibility for free- or reduced-price lunch. Note that some of these data fields (such as ethnicity or race, ELL status, eligibility for free or reducedprice lunch) are not required for the use of i-Ready. However, where districts would like reporting capabilities based on these categories, they may choose to provide this information to CA. To further demonstrate its commitment to protecting the privacy of student information, CA has taken the Student Privacy Pledge https://studentprivacypledge.org/. This means that, among other things, CA has pledged not to sell student information, not to engage in behaviorally targeted advertising, and to use collected data for authorized purposes only. CA only uses collected student data for the purposes described in the “How We Use Student Data” paragraph.	Student and teacher personal data is used only in the production systems and only for the explicitly identified functions of the i-Ready application. Student and teacher personal data is de-identified before any testing or research activities may be conducted. Upon the written request of a customer, Curriculum Associates will remove all personally identifiable student and educator data from its production systems when CA will no longer be providing access to i-Ready to that customer. In addition, CA reserves the right, in its sole discretion, to remove a particular customer’s student data from its production servers a reasonable period of time after its relationship with the customer has ended, as demonstrated by the end of contract term or a significant period of inactivity in all customer accounts. Student data is removed from backups in accordance with CA’s data retention practices. If CA is required to restore any materials from its backups, it will purge all studentidentifiable data not currently in use in the production systems from the restored backups.	CA collects and uses “de-identified student data”, which refers to data generated from usage of i-Ready from which all personally identifiable information has been removed or obscured so that it does not identify individual students and there is no reasonable basis to believe that the information can be used to identify individual students. • CA uses this aggregated, de-identified student data for core product functionality to make iReady a more effective, adaptive product. • CA uses de-identified data to provide services to our educator customers. We sometimes use third party software tools (such as Salesforce or Domo) to enhance the level of service we provide. However, we only use de-identified data with these tools. • CA also uses de-identified student and educator data for research and development purposes. This might include research analyzing the efficacy of i-Ready or development efforts related to our product and service offerings. We also conduct research using de-identified data for studies focused on improving educational systems and student outcomes more generally. • While some of this research work is done internally, CA does share de-identified student data with trusted third-party research partners as part of these research initiatives. • CA does not attempt to re-identify de-identified student data and takes reasonable measures to protect against the re-identification of its de-identified student data. • Our research partners are prohibited from attempting to re-identify de-identified student or educator data. • CA does not sell student identifiable data or aggregated de-identified student or educator data to third parties.	Terms of Service Privacy Policy
Edmentum	Information You Manually Provide. We collect the information you manually provide (using your keyboard, mouse, or touchscreen) when you use this Site. For example, we collect the information you provide when you complete a contact form, reach out to us with questions, or otherwise interact with this Site. Some of the information you manually provide may be personal information, such as your name and contact information. Information from your browser or device. We collect information that is sent to us automatically by your web browser and/or mobile device. This information typically includes your IP address, the name of your operating system, the name and version of your browser, the date and time of your visit, and the pages you visit. The information we receive may depend on your browser or device settings. The information we receive from your web browser and device is not, in and of itself, personally identifiable. Generally, we use this information in the aggregate to help us improve this Site and make it more compatible with the technology used by our visitors. However, we may combine it with other information in an attempt to identify you or we may combine it with information that does identify you. Information Collected by Cookies and Other Technologies. We use “cookies,” web beacons, and other technologies to collect information. For example, we may use these technologies to collect information about the ways visitors use this Site—which pages they visit, which links they use, and how long they stay on each page. We also use these technologies to support certain features of this Site. For example, we use these technologies to personalize your experience when you use this Site and to save you the trouble of reentering information already in our database or to prompt the settings you established on previous visits. The information we collect using cookies and similar technologies is not, in and of itself, personally identifiable, but we may link it to personal information that you provide. If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. Although you are not required to accept cookies when you visit this Site, you may be unable to use all of the functionality of this Site if your browser rejects our cookies.	We maintain reasonable administrative, physical and technological measures to protect the confidentiality and security of information you submit on or through this Site. Unfortunately, no website, server or database is completely secure or “hacker proof.” We therefore cannot guarantee that your information will not be disclosed, misused or lost by accident or by the unauthorized acts of others.	With Third–Party Vendors. We may share information collected through this Site with third-party vendors who act for us or on our behalf. For example, we use third-party vendors to design and operate this Site; to conduct surveys; and to help us with our promotional efforts. These third-party vendors may need information about you to perform their functions. With Our Affiliates. We may share the information collected through this Site with our affiliate companies. These affiliate companies are permitted to use your information for their own marketing purposes and in a manner otherwise consistent with this Notice. However, before sharing your information in this fashion, we may offer you the opportunity to “opt out” or “opt in,” to the extent required by applicable law. With Other, Carefully Selected Business Partners. From time to time, we may share your information with selected third parties for their own marketing purposes. For example, we may partner with third parties to sponsor contests or other promotions, and we may share with these third parties the information you submit to us to participate in the contest or take advantage of the promotion. Before doing so, however, we may offer you the opportunity to “opt out” or “opt in,” to the extent required by applicable law. In Aggregate or De-identified Form. We use information collected through this Site to create a compiled, aggregate view of usage patterns. We may share aggregate information with third parties so they can better understand our user base. We may also share with third parties information about how particular individuals use this Site, but only when the data has been de-identified cannon reasonably be re-identified. (“Individualized Data”). Individualized Data is not personally identifiable, but it does reflect the usage patterns of a particular Site user, as opposed to Site users collectively. We may provide basic demographic information (gender and age) in conjunction with providing Individualized Data. Third parties typically use this information for analytical purposes and to market their own products and services. As Part of a Business Transfers. Your information may be transferred to successor organization if, for example, we transfer the ownership or operation of this Site to another organization or if we merge with or are acquired by another organization, or if we liquidate our assets and sell them individually. If such a transfer occurs, the successor organization’s use of your information will still be subject to this Notice and the privacy preferences you have expressed to us. To Comply with Laws and Protect Our Rights and the Rights of Others. We may disclose your information when we, in good faith, believe disclosure is appropriate to comply with the law, a court order or a subpoena. We may also disclose your information to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of this Site; to enforce or apply our online Terms of Use or other agreements; or to protect our own rights or property or the rights, property or safety of our users or others. As Described in any other Applicable Notice. We reserve the right to disclose your information as described in any privacy notice posted on a page of this Site where you provide that information. By providing your information on that page you will be consenting to the disclosure of your information as described in that privacy notice. As Described in a Click–Through Agreement. We reserve the right to disclose your information as described in any click–through agreement to which you have agreed.	Terms of Service Privacy Policy
Edpuzzle	Edpuzzle collects the minimal amount of information from students necessary to create accounts on our Service: we ask students to provide a unique username, a unique email (the student email is only collected when using our Service through an LMS integration or Single Sign-On solution), a password, their first and last name and a unique code they have been given by their teacher to join a class. Beyond this information, students can also submit responses, comments, audios, images, or, if assigned a Student Project by their teacher, videos, all of which will remain private between teacher and student. All this information will only be used for the purposes of the school/teacher. In addition to the information entered by the student, we automatically collect some information from any use of our Service as set forth in the "Information Collected Automatically" section.We use this information to provide the Service to the student, for security and safety purposes, or as required by law or to enforce our Terms. We will not require students to provide more personal information than is reasonably necessary in order to participate in the Service. If we discover that we have collected information from a student in a manner inconsistent with COPPA, FERPA, GDPR, or any other applicable laws or regulations, we will take appropriate steps to delete the information. We do not disclose any personal information about children to third parties, except to service providers necessary to provide the Service, as permitted by law, or to protect the security of the Service or other users. Information collected from students (including personal information and information collected automatically) is never used or disclosed for third-party advertising, including any kind of first- or third-party behaviorally targeted advertising, and children’s personal information is never sold or rented to anyone, including marketers or advertisers.Open Class feature: The term “Open Class” refers to a specific feature available only for teacher accounts that enables students to access the Edpuzzle service through a student–teacher unique restricted session without providing any personal data. If the teacher creates an Open Class, students access the class through a unique code or link provided by their teacher. Teachers also have the choice to assign nicknames to students or opt for their random assignment by Edpuzzle. In cases where the teacher assigns the nickname, teachers have the discretion to ensure that the assigned nickname is not directly associated with individual students. On the other hand, if Edpuzzle handles the nickname assignment, the process ensures anonymization. As previously stated, the student enters the Open Class in a unique restricted session that is limited in functionality (the feature only allows the student to answer questions embedded in video lessons) and time (the unique session expires on assignment completion or after a period of seven (7) days of inactivity). Please note that joining an Open Class after assignment completion or expiration, even with the same nickname, will initiate a new restricted unique session. The restricted session is always private between student and teacher, and the student cannot see or interact with any user other than their teacher.	As stated in previous sections Edpuzzle does not sell or rent your, or your students' personal information to any third party for any purpose - including for advertising or marketing purposes. Furthermore, we do not share personal information with any third parties except in the limited circumstances described in this Privacy Policy: Other Users You Share and Communicate with on Edpuzzle: No student profiles are made available to the general public through our Service. Furthermore, students cannot share their account information with anyone on Edpuzzle. If you are a teacher you may choose to share information or content through the Service with other Edpuzzle teachers - for example, things like your account information or videos. Please keep in mind that information (including personal information or children's personal information) or content that you voluntarily disclose to others - including other Edpuzzle users you interact with through the Service can be viewed, copied, stored, and used by the people you share it with. We cannot control the actions of people with whom you choose to share information. Third-party Integrations on Our Service: When, as a teacher, you use third-party apps, websites or other services that use, or are integrated with, our Service, they may receive information about the content you post or share. For example, when you invite others via Facebook or Twitter, these services receive the information that you share through this functionality, and that you are sharing it from Edpuzzle. Information collected by these apps, websites or integrated services is subject to their own terms and policies, and under no circumstances will Edpuzzle be responsible for any content that may be shared, retrieved, or developed as a consequence of using such integrations. YouTube: Similarly, when using the YouTube API to watch lessons streaming from YouTube, teachers may see contextual advertisements on said lessons. At Edpuzzle we take students' privacy very seriously. That's why when students watch a video on Edpuzzle, they'll be streaming either from https://www.youtubeeducation.com, using the YouTube Player for Education, or https://www.youtube-nocookie.com, rather than streaming videos directly from https://www.youtube.com. You can learn more about the YouTube Player for Education here and about our partnership with YouTube here. Service Providers: We do work with vendors, service providers, and other partners to help us provide the Service by performing tasks on our behalf - we can’t build everything ourselves, after all! We may need to share or provide information (including personal information) to them to help them perform specific business functions, for example sending emails on our behalf, database management services, database hosting, providing customer support software, and security. Generally, these service providers do not have the right to use your personal information we share with them beyond what is necessary to assist us. Additionally, these service providers must adhere to confidentiality and security obligations that are consistent with this Privacy Policy. Distributors, Resellers and other Partners: We may, now or in the future, work with distributors, resellers and other partners to assist in the commercialization and sale of our products in your country or region. In such cases, we may share information (e.g., contact information you submitted with your request for a quote) with them to provide you with appropriate assistance and/or services. Testimonials: We post testimonials on our Service which may contain personal information such as the name, photo and/or a video of the individual in the testimonial. We obtain the individual’s consent in advance to ensure we have permission to post this content publicly. To request removal of your personal information from our testimonials, please contact us at privacy@edpuzzle.com. Analytics Services: We use analytics services, including mobile analytics software, to help us understand and improve how the Service is being used. These services may collect, store and use information in order to help us understand things like how often you use the Service, the events that occur within the application, usage, performance data, and from where the application was downloaded. Aggregated Information and Non-Identifying Information: We may share aggregated, non-personally identifiable information publicly, including with uselmrs, partners or the press in order to, for example, demonstrate how Edpuzzle is used, spot industry trends, or to provide marketing materials for Edpuzzle. Any aggregated information shared this way will not contain any personal information. If we choose to share this information with any third party, we will take necessary measures to ensure that the third party agrees not to engage in re-identification or the combination of Non-Identifying Information with other data sets that may pose a risk of re-identification. Legal Requirements: We may disclose personal information if we have a good faith belief that doing so is necessary to comply with the law, such as complying with a subpoena or other legal process. We may need to disclose personal information where, in good faith, we think it is necessary to protect the rights, property, or safety of Edpuzzle, our employees, our community, or others, or to prevent violations of our Terms of Service or other agreements. This includes, without limitation, exchanging information with other companies and organizations for fraud protection or responding to government requests. Parent Companies and/or Affiliates: We may share your 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 by 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. Change of Control: In the event that all or a portion of Edpuzzle or its assets are acquired by or merged with a third party, 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). We will provide you with notice of an acquisition within thirty (30) days following the completion of such a transaction, by posting on our homepage, and by email to your email address that you provided to us. If you do not consent to the use of your personal information by such a successor company, you may request its deletion from the company. In the unlikely event that Edpuzzle goes out of business, or files for bankruptcy, we will protect your personal information, and will not sell it to any third party. With your Consent: Other than the cases above, we won’t disclose your personal information for any purpose unless you consent to it. Additionally, as discussed above, we will never sell or rent your personal information to advertisers or other third parties.	We store your personal information for as long as it is necessary to provide products and Services to you and others, including those described above. As a general rule, if your account is inactive for eighteen (18) months or more (meaning you have not logged into your account during that time), Edpuzzle will automatically delete your account. Deletion will affect any on-going paid subscriptions, which will be immediately canceled. Following deletion, Edpuzzle may retain specific portions of data in the terms outlined in section "How can I delete my account?" of this Privacy Policy.In addition to the policy above that applies to all users, we only keep a student’s personal information while the student’s account is active, unless we are required by law to retain it or need it to ensure the security of our community or our Service, or to enforce our Terms.	Terms of Service Privacy Policy
Explore Learning, LLC	ExploreLearning collects information from you as you use this site. For example, you must enter certain personally identifiable information, including your name, e-mail address, and phone number. We use this information to verify your identity and prevent unauthorized access to your account and to contact you in connection with your use of this site. In addition to the information you provide, ExploreLearning collects information about your use of this site through tracking, cookies, and log files, as described in our general Terms of Use statement.	We will use the student data to provide the services to your school district. We will not keep the student data after you or the school district instructs us to delete it. You may not disclose or otherwise use the student data entered on this site for any unauthorized purposes.	We will use the student data to provide the services to your school district. We will not keep the student data after you or the school district instructs us to delete it. You may not disclose or otherwise use the student data entered on this site for any unauthorized purposes.	Terms of Service Privacy Policy
Ellevation	When you visit our Website, our servers automatically record information sent from your browser (“Log Data”). Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type and machine model, pages of the Website that you visit, the time spent on those pages, the referring URL, and access times and dates. We use this information to monitor, analyze use of and administer the Website, and to better tailor it to your needs. As you navigate through and interact with the Ellevation Website, including through interactions with Ellevation Bot, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns including, but not limited to, usage details, IP addresses, and other information. We use Google Analytics™ to track and store this information. For more information about Google Analytics, please see the Google Privacy Policy. This information helps us to improve the Ellevation website and to deliver a better and more informative experience. The technologies we use for this automatic data collection may include cookies. A cookie is a small data file sent from a website or application and stored on your computer or device. Cookies allow us to recognize your browser when you return to our Website, and to remember your login information. Cookies also allow us to serve certain features, to better understand how you interact with our Website, and to monitor aggregated usage. You can set your browser to detect some cookies, to stop accepting cookies, or to prompt you before accepting a cookie. To learn more about browser cookies, including how to manage or delete them, look in the Tools, Help or similar section of your web browser, or visit http://allaboutcookies.org. We use third party service providers to assist us in collecting and understanding Log Data. By using our Website, you agree to our use of these tracking technologies.	We may retain information you provide for as long as is necessary to fulfill the purposes as described in this Privacy Policy, or as otherwise permissible by law.	We may employ third parties to facilitate delivery of our Website and to provide certain features on our behalf, such as maintenance services, email management, database management, web analytics, review and processing of job applications and improvement of our Website.	Terms of Service Privacy Policy
ESGI	WHILE USING THE SERVICE, WE ASK USERS TO PROVIDE US WITH CERTAIN PERSONALLY IDENTIFIABLE INFORMATION THAT CAN BE USED TO CONTACT OR IDENTIFY THEM (“PERSONAL INFORMATION”). PERSONAL INFORMATION MAY INCLUDE YOUR NAME, EMAIL ADDRESS, MAILING ADDRESS, TELEPHONE NUMBER, OTHER CONTACT INFORMATION, INFORMATION ABOUT A CUSTOMER TO THE SERVICE (SUCH AS A SCHOOL, DISTRICT, OR EDUCATIONAL ORGANIZATION, EACH, A “CUSTOMER”), PAYMENT CARD INFORMATION (IF YOU PURCHASE SERVICES THROUGH THE ESGI WEBSITE), AND STUDENT/PARENT INFORMATION. YOU MAY PROVIDE US WITH PERSONAL INFORMATION WHEN YOU REGISTER FOR AN ACCOUNT, USE THE SERVICE, MAKE A PURCHASE ON THE SERVICE, CONTACT CUSTOMER SUPPORT, OR OTHERWISE COMMUNICATE WITH US VIA CHATS, COMMENTS, OR REQUESTS. YOU MAY ALSO PROVIDE US WITH A THIRD PARTY’S PERSONAL INFORMATION IN CONNECTION WITH AN ASSESSMENT OR OTHER CLASSROOM ACTIVITIES. SUCH THIRD-PARTY PERSONAL INFORMATION MAY INCLUDE BUT IS NOT LIMITED TO THE INDIVIDUAL’S NAME, STUDENT ID, GRADE, PREFERRED LANGUAGE, AND GENDER. WE COLLECT AND HANDLE ANY SUCH PERSONAL INFORMATION ABOUT OTHERS CONSISTENT WITH THIS PRIVACY POLICY. YOU REPRESENT AND WARRANT THAT YOU HAVE OBTAINED ANY REQUIRED CONSENT, PROVIDED ANY REQUIRED NOTICE, AND OTHERWISE FULLY COMPLIED WITH ALL APPLICABLE LAWS, INCLUDING ANY DATA PROTECTION LAWS, WITH REGARD TO ANY INFORMATION THAT YOU PROVIDE TO US ABOUT OTHERS.		WE ONLY SHARE PERSONAL INFORMATION IN A FEW LIMITED CIRCUMSTANCES AS SET FORTH BELOW. WE DO NOT RENT OR SELL INFORMATION FOR MARKETING PURPOSES. WE NEVER SHARE OR SELL PERSONAL INFORMATION OF STUDENTS (“STUDENT DATA”) WITH THIRD PARTIES FOR MARKETING PURPOSES AND WILL NOT SELL STUDENT DATA UNDER ANY CIRCUMSTANCES. IN ADDITION, WE DO NOT USE ANY BEHAVIORAL INFORMATION TO PROVIDE TARGETED ADVERTISING TO STUDENTS. IF YOU USE THE SERVICE, YOU ARE AUTHORIZING US TO SHARE INFORMATION IN THE FOLLOWING WAYS: WITH A THIRD PARTY, AS DIRECTED BY YOU OR A CUSTOMER WITH OUR BUSINESS PARTNERS, VENDORS, AND CONSULTANTS WHO PERFORM SERVICES ON OUR BEHALF OR WHO HELP US PROVIDE OUR SERVICE, SUCH AS ACCOUNTING, MANAGERIAL, TECHNICAL, MARKETING, OR ANALYTIC SERVICES, PROVIDED THAT THEY ARE SUBJECT TO CONFIDENTIALITY AND SECURITY OBLIGATIONS IF REQUIRED TO DO SO BY LAW OR IN THE GOOD-FAITH BELIEF THAT SUCH ACTION IS NECESSARY TO COMPLY WITH LOCAL, STATE, OR FEDERAL LAWS, OR TO RESPOND TO A COURT ORDER, JUDICIAL, OR OTHER GOVERNMENTAL SUBPOENA OR WARRANT, OR IN THE EVENT OF BANKRUPTCY PROCEEDINGS IF WE BELIEVE IN GOOD FAITH THAT DOING SO IS REASONABLY NECESSARY OR APPROPRIATE TO PROTECT THE RIGHTS, PROPERTY, OR SAFETY OF ESGI, OUR USERS, OUR EMPLOYEES, COPYRIGHT OWNERS, THIRD PARTIES, OR THE PUBLIC, INCLUDING TO PROTECT ESGI OR OUR USERS FROM FRAUDULENT, ABUSIVE, INAPPROPRIATE, OR UNLAWFUL USE OF OUR SERVICE TO ENFORCE OR APPLY THIS POLICY, OUR TERMS OF USE, OR OUR OTHER POLICIES OR AGREEMENTS IN CONNECTION WITH ANY MERGER, SALE OF COMPANY ASSETS, FINANCING OR ACQUISITION, OR IN ANY OTHER SITUATION WHERE INFORMATION MAY BE DISCLOSED OR TRANSFERRED AS ONE OF THE BUSINESS ASSETS OF ESGI; PROVIDED, IF THE RIGHTS AND OBLIGATIONS WITH RESPECT TO YOUR PERSONAL INFORMATION ARE ASSIGNED TO A THIRD-PARTY SUCCESSOR-IN-INTEREST, THE SUCCESSOR WILL BE BOUND, WITH RESPECT TO YOUR PERSONAL INFORMATION, BY THE TERMS OF THE THEN-APPLICABLE PRIVACY POLICY OR WILL ADOPT A PRIVACY POLICY THAT IS SUBSTANTIALLY SIMILAR IN ALL MATERIAL RESPECTS WITH SUCH PRIVACY POLICY; PROVIDED, FURTHER, IF THE SUCCESSOR DOES NOT AGREE TO BE BOUND BY THE TERMS OF THE THEN-APPLICABLE PRIVACY POLICY AND DOES NOT ADOPT A PRIVACY POLICY THAT IS SUBSTANTIALLY SIMILAR IN ALL MATERIAL RESPECTS WITH SUCH PRIVACY POLICY, YOU WILL HAVE RECOURSE TO ANY REMEDIES AVAILABLE TO YOU AT LAW OR IN EQUITY, WHICH MAY INCLUDE THE RIGHT TO TERMINATE YOUR COMMERCIAL RELATIONSHIP WITH THE SUCCESSOR OR TO HAVE THE SUCCESSOR RETURN YOUR INFORMATION TO YOU; AND/OR IN AN AGGREGATED AND/OR ANONYMOUS FORM THAT DOES NOT REASONABLY IDENTIFY A USER OR CUSTOMER	Terms of Service Privacy Policy
FLVS	Virtual School holds the privacy and safety of our parents, guardians, and students in highest regard. We would like to familiarize you with the types of personal data we collect and process, why we need it, who it may be disclosed or released to and under what circumstances, and your rights regarding your personal information. This Policy applies to all Florida Virtual School (flvs.net, flvsglobal.net) owned sites, applications, services and technologies. Please take a few minutes to carefully review the policy. By using our sites and services, you acknowledge that you accept and agree to this Privacy Policy. Please be aware, data processing and reporting information described in this policy is detailed for our FLVS Full Time students where FLVS is the primary school of record. For our Flex and Global students, your primary school of record may have different requirements for data processing, retention and reporting, particularly if you are located outside the state of Florida. We have included privacy contact options below if you have any questions or concerns about our privacy policy or practices. We also encourage you contact us if you have any visual or language accommodations that we can assist you with, such as communicating this policy to you verbally or in alternate languages.	RIGHT TO WITHDRAW CONSENT. You have the right to provide written consent before a school discloses personally identifiable information from your education record except for the legally authorized purposes discussed in the disclosures section above. For our FLVS Full Time students, we follow a do-not-disclose by default policy. Parents/guardians and eligible students may choose to Opt-In and consent to disclose for specific purposes, such as our Media Consent Form. You have the right to change your consent choices or preferences at any time. Please contact us using one of the contact options below for assistance. RIGHT TO TRANSFER. You have the right to transfer your information. When FLVS Full Time parents/guardians or eligible students send us a signed Transcript request, we will forward your transcripts to the destination school or agency you identified in your request. For our other student types, please see our Transcript Request page at https://www.flvs.net/student-resources/transcript-request for instructions and options available to send your transcripts or allow your school of record to access your Final Grade Report. RIGHT TO ERASURE. For FLVS Full Time students where we your primary school of record, we are obligated to retain personal data contained in your education records in accordance with Florida General Records schedules. This includes student transcript information defined by Florida statute 1002.42(3)(a)(2) that must be maintained as a permanent record. For Global students that reside outside the United States or in the European Union (EU), please contact us if you have a specific question or concern about our data retention requirements if you believe it conflicts with your right to request erasure, under certain circumstances as defined by the EU General Data Protection Regulation (GDPR).	We do not sell your personal information. We do not use or share your information for any advertising or marketing purposes that is not specifically related to your educational services or school purposes, such as school sponsored events, activities, communications and announcements. We do not publish student photos, video, audio recordings or student work without the written student and parent or guardian consent (see our Media Release Form) We do not allow students to use cell phones or other electronic devices to capture, record or transmit videos, pictures or audio recordings of any other students or staff members without prior approval and consent from the school, parent/guardian and student We do not disclose “Directory Information” as defined in the Family Educational Rights Privacy Act (FERPA) to any external entities, including military recruiters and universities We do not collect or process your data for any purposes that are not legally required or necessary for legitimate educational interest Retain personal data beyond what is necessary to provide FLVS educational services and support, to comply with federal, state, and local education records retention requirements; to comply with legal orders or retention requirements specified in a contract or similar agreement between your primary schools of record and FLVS.	Terms of Service Privacy Policy
Imagine Learning	Required student information Student first and last name Grade level Language Student number Student username and password for our Services LEA name Information provided through use of our Services: Assessment results and scores including academic performance and placement, psychographic information, and screening results Curriculum progress Audio recordings Student-generated content (e.g., responses to writing prompts and math journals) Communications (such as chat text logs between students and certified teachers, grade commentary, etc.) Certificates of achievement and curriculum completion Optional student information (Note that we will never condition a student’s participation in an activity on the student’s disclosure of more Personal Information than is necessary to participate in the activity) Single sign-on ID (for schools that use a single sign-on functionality) Demographic information (such as date of birth, gender, ethnicity/race, language). Special indicators (such as Individual Education Plan (IEP) status, English-Language Learner (ELL) status, living situations (foster care/homeless), low-income status etc.) Organization number (e.g., school or district identifier, state identification, or other number) Student email	Upon termination of your account, Imagine Learning will take commercially reasonable steps to delete any Personal Information from its live databases in a reasonable amount of time. We will retain Personal Information collected in connection with an account only for as long as is necessary to provide the services to the account holder, as required by applicable laws or regulations or otherwise per the terms or a contract with a LEA. Data may be returned to the LEA as directed by the agreement with the LEA. If no specific instructions are included in the agreement, the data will be returned or destroyed upon one of the following (i) after termination of our relationship with a LEA or LEA-authorized person, (ii) when it is no longer needed for the purpose for which it was provided, (iii) when advised to do so by the LEA, or (iv) as directed by agreement with the LEA. Data are returned in a digital, machine-readable format via a secure means of transmission. We may further retain information for business practices based on our legitimate interest or legal purposes, such as secure electronic archives that are not readily accessible to users or maintained for disaster recovery and/or information technology backups. We may also maintain De-Identified Data, including usage data, for any purpose that is consistent with laws, regulations, and contractual obligations. Even if your account is closed, information may remain in backup or archive records and we may retain certain data relevant to preventing fraud or future abuse or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable or De-Identified Data, account recovery, or if required by law. All retained data will continue to be subject to the applicable privacy policy for the Service.	We use third-party service providers to provide a variety of services, such as assisting us with providing customer support, hosting our Services, providing us with analytics about how people use our Services, assisting us with marketing our Services to LEA administrators and teachers, sending and tracking responses to email, providing a framework for the delivery of assessment tools and analytics, storing data, providing single sign-on services (where applicable), and helping us identify and track bugs and errors in our Services. Student analytics data are anonymous, but teacher analytics data include teacher name and email address. Third parties we work with are contractually prohibited from using any Personal Information for any purpose other than providing the services we request from them. When a LEA is the primary account holder, we share information with third parties at the direction of the LEA, and it is the LEA’s responsibility to make such requests in a manner that is consistent with their internal policies and the law. We may also share information that we collect in the following (or comparable) circumstances: if we believe in good faith that it is necessary to disclose the information under any applicable law or regulation (for example, in response to a court order or a subpoena); if we believe in good faith that it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person; to investigate and act upon potential violations of the law or of our terms of service; to provide information to a claimed owner of intellectual property who claims that content you have provided infringes on their rights; in response to bankruptcy proceedings; with teachers (and parents where necessary) so they can see information about their students or children, such as the student’s or child’s name, school affiliation and activity on assignments (including time of activity and any responses to questions, extending to grades for those assignments); when any user logs into Imagine Learning with a third-party account (such as a ClassLink, Clever or other Learning Management System account), that third party will learn that that user has visited Imagine Learning, and that information will be subject to that third party’s privacy policy and practices; with third-party products specifically configured by LEAs to interoperate with Imagine Learning; if the information is De-Identified Data; with our corporate affiliates, parents, and/or subsidiaries; or in other circumstances that you expressly consent to. We will not sell Personal Information to anyone for monetary compensation. However, we do share Personal Information that could be considered a ‘sale’ under the California Consumer Privacy Act such as in connection with the sale of Imagine Learning’s equity or assets or a merger of Imagine Learning with another company. Any sale or merger would be conditioned so that such information will continue to be covered by the then-applicable Privacy Policy or a policy at least as robust as such Privacy Policy.	Terms of Service Privacy Policy
IXL	Information collected from the Child's use of the Service. During the course of providing the Service, we collect information about the user of the child profile's use of the Service and information submitted to the Service, such as answers to questions, for the purpose of providing feedback to the user and for compiling reports and awards. When your Child accesses the Service through the Parent's account, we automatically collect and store usage information as well as information about the device used by the Parent and Child to access the Service. For example, we collect an IP address, location (at the city level), browser type, language preferences, and other information about the device used to access the Service, such as the device type, model and manufacturer and a unique identifier which allows us to uniquely identify your browser, device, or account, as well as account usage information such as the day/time stamp, referring/exit pages and URLs, pages viewed, and similar information. This information is typically collected through a variety of tracking technologies, including cookies, web beacons, log files, and similar technology (collectively, "tracking technologies"), and we may use third party providers to collect this information on our behalf. This data collection is explained in greater detail in Section 1 of our Privacy Policy under the sub-heading "Information we receive when you use the Service." We use this information to secure and improve the Service, to provide personalized content and information, to remember you when you return to the Service at a later time or using a different device, to improve the Service, to save you time, to provide better technical support, to track website usage and other similar purposes.	The Parent may review the information collected from the user of the child profile at any time by signing in to the Parent account. The Parent may refuse to permit the further collection of the child user's information by no longer providing the child user access to the Service through the Parent's account. IXL will retain the personal information collected from and about the user of the child profile for as long as necessary to provide the Service and will de-identify or delete the personal information after the termination of the Parent's subscription account in accordance with our standard data retention policy or until we receive a deletion request. To request deletion of personal information of a user of a child profile at any time, please contact us at compliance@ixl.com.	IXL may share or disclose a child's personal information as needed to provide our Service or with your consent or permission. For example, we share information with our trusted vendors, third party service providers and individuals to provide services for us on our behalf, which may include analytics providers and hosting services. We may also share personal information if we have a good faith belief that access, use, preservation, or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process, or enforceable governmental request; (b) enforce applicable Terms of Service, including investigation of potential violations thereof; (c) detect, prevent or otherwise address fraud, security or technical issues; (d) protect the rights, property, or personal safety of IXL, its users, or the public; or (e) as required or permitted by law. If IXL becomes involved in a merger, acquisition, bankruptcy, change of control, or any form of sale of some or all of its assets, personal information may be transferred or disclosed in connection with the business transaction, subject to any applicable laws. We may also share aggregate or de-identified information in a manner that cannot be reasonably used to identify an individual user.	Terms of Service Privacy Policy
iReady	CA receives certain information, which we receive pursuant to the school official exception under FERPA, from its school district customers to enable students to use i-Ready. The following information is generally provided to CA for each student user of i-Ready: student first and last name; date of birth; gender; ethnicity or race; student identification number; student school or class enrollment; student grade level; teacher name; English language learner status, and; eligibility for free- or reduced-price lunch. Note that some of these data fields (such as ethnicity or race, ELL status, eligibility for free or reduced-price lunch) are not required for the use of i-Ready. However, where districts would like reporting capabilities based on these categories, they may choose to provide this information to CA.	Student and teacher personal data is used only in the production systems and only for the explicitly identified functions of the i-Ready application. Student and teacher personal data is de-identified before any testing or research activities may be conducted. Upon the written request of a customer, Curriculum Associates will remove all personally identifiable student and educator data from its production systems when CA will no longer be providing access to i-Ready to that customer. In addition, CA reserves the right, in its sole discretion, to remove a particular customer’s student data from its production servers a reasonable period of time after its relationship with the customer has ended, as demonstrated by the end of contract term or a significant period of inactivity in all customer accounts. Student data is removed from backups in accordance with CA’s data retention practices. If CA is required to restore any materials from its backups, it will purge all student-identifiable data not currently in use in the production systems from the restored backups.	CA collects and uses “de-identified student data”, which refers to data generated from usage of i-Ready from which all personally identifiable information has been removed or obscured so that it does not identify individual students and there is no reasonable basis to believe that the information can be used to identify individual students. CA uses this aggregated, de-identified student data for core product functionality to make i-Ready a more effective, adaptive product. CA uses de-identified data to provide services to our educator customers. We sometimes use third party software tools (such as Salesforce or Domo) to enhance the level of service we provide. However, we only use de-identified data with these tools. CA also uses de-identified student and educator data for research and development purposes. This might include research analyzing the efficacy of i-Ready or development efforts related to our product and service offerings. We also conduct research using de-identified data for studies focused on improving educational systems and student outcomes more generally. While some of this research work is done internally, CA does share de-identified student data with trusted third-party research partners as part of these research initiatives. CA does not attempt to re-identify de-identified student data and takes reasonable measures to protect against the re-identification of its de-identified student data. Our research partners are prohibited from attempting to re-identify de-identified student or educator data. CA does not sell student identifiable data or aggregated de-identified student or educator data to third parties.	Terms of Service Privacy Policy
Kami	In order to create a unique account, Kami does require that all users enter their email address and create a password, which is stored on the site, or use their own Google or Microsoft Account to sign on (Single-Sign-On), and may collect additional information such as name of school or class, and whether they are a teacher or student, in order to assign the user to the correct user group. Documents may be uploaded to Kami by users in order to share them with other users for collaborative processing. Kami does not store these files once the sharing process is completed. Annotations made by users are stored on the site in order to display them to other users viewing a shared document, and to display them to the user if the same file is later re-opened. We collect and use the following information to provide, improve and protect our Services: Account – We collect, and associate with your account, information you give us like your name, email address, phone number, payment info, and physical address. Some of our services let you access your accounts and your information with other service providers. Services – When you use our Services, we store, process and transmit your files and information related to them (for example, the annotations you make). If you give us access to your contacts, we’ll store those contacts on our servers only for you to use. This will make it easy for you to do things like sharing your stuff, and inviting others to use the Services. Usage – We collect information from and about the devices you use to access the Services, to aid trouble-shooting and optimisation of the Services. This includes things like IP addresses, the type of browser and device you use, the web page you visited before coming to our sites, and identifiers associated with your devices. Your devices (depending on their settings) may also transmit location information to the Services. Please note that users, including children, can choose whether to share this information with us, but certain features may not function without it. As a result, users may not be able to access certain features if required information has not been provided. We will not require a user to provide more information than is reasonably necessary in order to participate in the online activity, and we use this personal data for no other purpose than providing the service to the user. Kami collects limited personal information from students only where that student’s school, district, or teacher has engaged with Kami to collect personal information for the use and benefit of the learning environment. This information is not shared outside of the school or with any third parties except those needed for the provision of the service as outlined in this policy. Students of any age cannot share their profiles publicly outside of their classroom or school. Teachers can annotate documents and provide comments to students. Students can annotate documents, submit assignments through your learning management system, add comments and take online tests; Teachers or students can record audio or video and attach these recordings to content in our system. None of this information is shared with any third parties without the teacher or school’s consent. Access to user information is given only as discussed below, but we won’t give or sell it to advertisers or other third-parties. Others working for Kami – Kami uses certain trusted third party services to help us provide, improve, protect, and promote our Services. These third parties will access your information only to perform tasks on our behalf and in compliance with this Privacy Policy. They are listed below. Other users you share it with – Our Services display information like your name and email address to other users in places like your user profile and sharing notifications. Certain features let you make additional information available to other users. You can also give third parties access to your information and account – for example, via Kami APIs. Just remember that their use of your information will be governed by their privacy policies and terms. Law & Order – We may disclose your information to third parties if we determine that such disclosure is reasonably necessary to (a) comply with the law; (b) protect any person from death or serious bodily injury; (c) prevent fraud or abuse of Kami or our users; or (d) protect Kami’s property rights. Stewardship of your data is critical to us and a responsibility that we embrace. We believe that our users’ data should receive the same legal protections regardless of whether it’s stored on our services or on their home computer’s hard drive. We’ll abide by our principles when receiving, scrutinizing and responding to government requests for our users’ data: Be transparent, Fight blanket requests, Protect all users, and Provide trusted services.	We work with a number of third-party service providers to help improve the quality of our service. We have contracts with these third parties which guarantee that they do not share your information with any other third parties and protect the data at least the same level as we do ourselves. In case a transfer of data is needed while collaborating with one of those third parties we make sure the transfer is executed to a country which is providing adequate protection according to EU. If this is not the case we sign agreements which includes the EU Standard Contractual Clauses (also called Model Clauses) published by the European Commission to protect EU data. Kami uses the following third-party services : Microsoft – if you choose to log into Kami using your Microsoft account (often referred to as Single Sign-on or “SSO”), your login will be authenticated by Microsoft. If you open/save files on OneDrive, Microsoft will first request authorization for this. You can review Microsoft’s Privacy Policy for use of your Microsoft account here; and update or revoke your permissions as described here. Google – if you choose to log into Kami using your Google account, your login will be authenticated by Google. If you open/save files on Google Drive, Google will first request authorization for this. You can review Google’s Privacy Policy for use of your Google account here; and update or revoke your Google Permissions here. Groove – Groove is a platform our Support Team use internally to coordinate customer support activities in response to requests from our customers. Our contractual agreement with Groove complies with the terms of this policy. Google Analytics & Tag Manager – an analytics service used to help analyze your use of our Website and allow us to improve our Service and provide you information on the Service. Our agreement with Google complies with the terms of this policy. Stripe – when you upgrade your account online using a credit card, your payment is securely processed using Stripe’s e-payments service. Our contractual agreement with Stripe complies with the terms of this policy. We will only contract with future service providers that are consistent with this policy or allow users a choice to send information to the future provider. For more information on any of these third parties please contact us at: privacy@kamiapp.com	Under FERPA regulations, Parents have the right to refuse the site further contact with their child and to have access to their child’s school record information and to have it deleted by contacting the school administrator. If you are a parent and would like more information on parental rights with respect to a child’s educational record under the U.S. Family Educational Rights and Privacy Act (FERPA), please visit the FERPA site. If you believe that a student’s school, district, or teacher has not required parental consent prior to our collection of any personal information, contact us at privacy@kamiapp.com If you are the parent and guardian of a student using Kami, and cease to agree with Kami’s terms of use and privacy policy at some point in the future, you may opt-out by contacting the Kami subscriber (typically your school) if you are a school account user, or contact us directly at privacy@kamiapp.com if you are an individual account user. If you wish to review your or your student’s or your child’s personally identifiable information stored by Kami, you may email us your request at privacy@kamiapp.com . We will respond to your request within 30 days. If your or your student’s or your child’s personally identifiable information changes, or if you no longer desire our service, you may correct, update, or delete it by making the change directly in the user profile in the Kami App, or email us at privacy@kamiapp.com . We will respond to your request within 30 days. In any correspondence such as e-mail or mail, please include the child’s username, the school or organization, and the teacher or parent’s email address and telephone number. To protect children’s privacy and security, we will take reasonable steps to help verify a teacher or parent’s identity before granting access to any personal information.	Terms of Service Privacy Policy
LearnKey/GMetrix/Certiport (Pearson Assessments)	The personal data we collect and use broadly falls into the following categories: Registration, profile, proof of identity and purchase information Information collected as part of Examinations and certifications and Educational Courses and Tutoring Customer service and educational/enrolment support information User generated data (e.g. your participation in forums) Data generated by AI (e.g. as part of assessment scoring) Video, image and audio recordings (e.g. collected during virtual classrooms or as part of exam proctoring) Activity and usage information Location, application and systems log data Special category data (e.g. relating to health for access arrangements, biometric face and voice technology to prevent cheating, and other sensitive information for equality monitoring); More information as to the types of data falling under these categories can be found in section 2 of the Pearson Privacy Center Notice. The nature of our Services means we often process information about users under the age of 18. We recognize our responsibility to keep children safe online and have put additional protections in place to ensure this. We do this by working closely with parents, and schools, please see section 4 of the Pearson Privacy Center Notice for more information.	How long does Pearson keep my personal data for? Only for as long as necessary to fulfil the purposes for which it was requested. Some types of information such as those relating to qualifications and virtual schools need to be retained for long periods of time. More information about this is included in section 10of the Pearson Privacy Center Notice.	Yes. We share personal data with our group members who help us to deliver and improve our Services. Depending on the Service in question, we also share user personal data with their academic institutions, instructors, employers and/or parent or guardians as appropriate. Your personal data is shared with our suppliers who help us to provide the Services to you. We may also share your personal data with regulators, law enforcement, courts, with our professional advisors, or with other third parties for example in connection with the sale of or investment in our business. More information about this is included in section 11 of the Pearson Privacy Center Notice.	Terms of Service Privacy Policy
Lexia	Personal information is collected by Lexia. We collect personal information about you (your “Personal Information”) through: The use of inquiry and registration forms The purchase process when you buy any of our products or services The provision of your details to us either online or offline The elements of your Personal Information that we collect under this policy may include: Name Job title Company name Personal or professional contact and demographic information, shipping and billing addresses, phone and fax number Mobile telephone number E-mail address IP address, device information, activity information and browser information Payment details such as credit card information and transaction history Market research data such as customer usage patterns	We may retain your Personal Information for as long as your account is active or as needed to provide you with our services, comply with our legal and regulatory obligations, verify performance, resolve disputes and enforce our rights and agreements.	We use Personal Information under this privacy policy for various business purposes which may include: Providing our customers with a personalized service and support. Engaging in transactions and communications with our customers. Processing orders, registrations and inquiries. Conducting market research and surveys. Running competitions. Measuring interest in and improving our website, products, and services. Providing our customers with information about products and services we offer. You may stop the delivery of marketing emails by following the instructions accompanying a particular communication or by contacting us at privacy@lexialearning.com. Protecting rights or fulfilling obligations required by law, regulation or contract. Resolving disputes, collecting fees, protecting against fraud, and troubleshooting problems We use the information you provide when placing an order to complete that order and to service your account. We do not share this information with outside parties except: 1. to the extent necessary to complete that order or to provide you with services by way of our service providers or contracted partners (e.g., payment processing, sales partners servicing your account, third-party shipping, cloud computing infrastructure and hosting providers, business analytics, customer support); or 2. to successors in title to our business; or 3. in accordance with legal and regulatory requirements or to respond to a government subpoena or other government request; or 4. as necessary, in Lexia’s sole discretion, to protect the perceived rights, safety and property of Lexia, users of our Websites or services, and the public; or 5. with the parent organization, affiliate or subsidiary entities of Lexia to manage the personal information as joint controllers. We may also disclose your personal information to any other third party with your prior consent. You may sign-up to receive email or newsletter or other marketing communications from us. If you would like to discontinue receiving this information, you may update your email preferences by using the “Unsubscribe” link found in emails we send to you or at your member profile on our website or by contacting us at privacy@lexialearning.com. Other than as set out above, you will be notified when personal information about you will be shared with third parties, and you will have an opportunity to choose not to have us share such information. We also use information in aggregate form (so that no individual user is identified): To build up marketing profiles To aid strategic development To audit usage of the Website	Terms of Service Privacy Policy
MajorClarity	Clients decide to use MajorClarity, they submit information necessary to create their school account, including first and last names, ID numbers, email addresses, and school for staff users. ‍ Clients also submit minimally required information about Students, used for school purposes to allow Clients to view Student activity within MajorClarity: Grades 3-5: First and Last name, unique ID number, grade level, school email address, school Grades 6-12: First and Last name, unique ID number, grade level, school email address, school ‍ Additional information Clients would like to host about Students within MajorClarity is done at the Clients' discretion to enable certain platform features and for their internal review, analysis and reporting. This may include Student personal information and academic records, date of birth and other demographic information, grades, test results and performance data. Clients may also host information about a Student's parent or legal guardian, including, but not limited to names and email addresses. ‍ Clients may create accounts in MajorClarity for Students' parent or legal guardians by importing their existing records and submitting user names. At the Client's discretion, parents may be provided with access privileges to view and/or edit certain information. Information Provided by Students ‍ Students log into MajorClarity using information provided by the Client or they create their own user name and password if signing up individually: Grades 3-5: Students create a user name and password. They also add their respective school, if it is on the list. Grades 6-12: Students create a user name and password. They also add their respective school, if it is on the list. Also, subject to the configuration options selected by Clients, students may choose to add information such as their email address or phone number. ‍ Students also provide information by participating in interactive features provided by MajorClarity, request support, manage your account, or otherwise communicate with MajorClarity. The type of information MajorClarity collects includes your name, email address, ratings of test-drives, classes you have taken, personality test results, resumes, posts and comments, and messages between Students or Clients. A Special Note About Students Under the Age of 13 MajorClarity operates in compliance with the Children's Online Privacy Protection Act (COPPA). Subject to the configuration options selected by Clients, Students under the age of 13 may be asked to submit personal information. Any such information is used only for school purposes. ‍ MajorClarity relies on Clients to provide consent for collection of that data on behalf of the parents or legal guardians, as agreed to in advance by Clients. ‍ Clients may also make any information provided by Students under the age of 13 available to parents or legal guardians to review through each Client's product dashboard. To the extent you are an individual user and under 13 years of age, you are required to receive parental/guardian consent before using any service MajorClarity offers.	As a system of record for Clients and Students, MajorClarity retains data at the sole discretion of Clients and Students, and for as long as they have active agreements with MajorClarity. After termination of an agreement, MajorClarity retains data for the period of time specified in the agreement (45 days unless otherwise specified) to allow districts to retrieve their data. After this time, the personal information of students or staff/administrators is deleted. Daily backup files are retained for a period of 30 days. However, at any time upon termination of an agreement or otherwise at their discretion, Clients and Students may submit a written request to have their personal information provided to MajorClarity deleted by emailing hello@majorclarity.com. We will comply with such written requests within (30) days. Note that in the event that a Student chooses to submit data to a postsecondary institution, we are unable to delete or otherwise retract that information from the receiving institution. ‍ Notwithstanding the above, we do retain aggregated, de-identified data for the purposes described in the section titled, "How We Use and Disclose Information."	MajorClarity allows Students to connect with post-secondary educational and/or employment opportunities through our platform, since it is intended to help students explore what they want to do after secondary education. MajorClarity also provides Clients with access to a variety of features which Clients may choose to make available to Students. These features, some of which are operated by third party providers, are available only to Students in grades 6-12, and may be turned on or off at the sole discretion and control of Clients. ‍ In addition, Employers and post-secondary institutions have the ability to post opportunities or events that Students will be able to respond to, RSVP for, or submit information to -- if they are interested (examples include: information nights for colleges, or internships for employers). Students are in complete control of this process and the post-secondary institutions and/or employers that they engage with. Students can opt-out of connecting with institutions and employers they are interested in at any time, although most Students see this as a valuable tool. Students who do not opt-out grant us a limited license to connect them with institutions and employers they engage with and consent to being connected. We do not, however, allow any Student under the age of 13 to be connected with institutions or employers, even if a Student desires to do so, in compliance with COPPA. ‍ If Clients choose to make these features available to their Students, or if a Student desires to take advantage of these features individually, a limited amount of information, including personal information, may need to be sent to the third party in order to deliver the service to the Client and/or Student. MajorClarity does not disclose more information to third parties than is necessary for them to provide features on behalf of MajorClarity. All third parties have agreed to handle the information in compliance with this Privacy Policy and applicable law. They may use the information for the sole purpose of providing the service to Clients and Students. We are not responsible for data once it has been submitted to a postsecondary institution. In addition, Clients and Students should be aware that if they choose to connect with a postsecondary institution in another country, their data will be subject to the laws of that country. MajorClarity also provides Clients and Students with links to third party websites and allows Clients to add links to websites that they may then share with Students in all grades. We do not control, and therefore are not responsible for, the content or privacy practices of those websites. Those websites are governed by their own privacy policies, and we encourage Clients and Students to read them.	Terms of Service Privacy Policy
Math Nation	When you utilize one of our products, your personally identifying information is collected through a registration form. Your decision to provide such information is voluntary. We collect this information in order to best respond to you and any issues you may encounter. If you choose not to share this information with us, it may not be possible for us to respond to your request. For Application activities that request personal information, you agree to provide accurate and current information about yourself. Your registration and/or participation in our Application services may be canceled without notice if at any time we discover that you have provided false information or violated any term of this Privacy Policy or our Terms of Use. We will not disclose any of your personal information, except when we have your permission or under special circumstances, such as when we believe in good faith that disclosure is reasonably necessary to cooperate with local, state and/or federal law enforcement authorities, to enforce the Terms of Use or prevent unauthorized use of the Application, to respond to claims that any content in the Application violates the rights of third parties, or to protect the rights, property, or personal safety of our company, its users, or the public. You can sign into your account to see any personally identifiable information we have stored such as your name, email address, or phone number. You can also contact us by email to request to see this information. Each of our products or applications collects different information, as outlined below: Math Nation/Algebra Nation: Algebra Nation is a dynamic online and printed workbook resource that helps students master Algebra 1 or serves as on on-ramp tool to Algebra. Students can get personalized, real-time feedback from teachers, tutors, and peers on the Algebra Wall, which empowers them to learn collaboratively inside and outside of school. Math Nation provides the same services but to a broader math audience, including Geometry and Algebra 2. For middle school or high school students whose district or school is using the free Clever service (in use by more than 60% of schools in the country) we collect students’ full name, high school name, and teacher name — and that’s it. If the district or school is using Clever, we only have access to the data which is shared with us by the district or school. So the data shared is 100% up to the district or school, and varies. All of this information is stored in secure servers in a manner that is fully compliant with the The Family Educational Rights and Privacy Act (FERPA). For high school students who sign up on their own, independently of their school, we collect their full name and their email address.	We store data for as long as it is necessary to provide products and services to you and others. Information associated with your account will be kept until your account is deleted, unless we no longer need the data to provide products and services. Eligible students or their parents or guardians may have the legal right (including under FERPA, COPPA and the California Consumer Privacy Act (CCPA)) to access, correct, export or delete certain of their own information or content, or to make certain choices. To make a request, please contact your school or school district. We will help them provide the requested access or make appropriate corrections. If we receive any such requests directly, we will refer those inquiries to the Education Customer to the extent required or permitted by applicable law or contractual requirements. Users can request deletion of their data by clicking here. User data deletion requests are processed within 24 hours of receipt. We keep Student Data for the period reasonably necessary to perform and support the services requested by the Education Customer or as required by contract, and we dispose of it at the Education Customer’s direction. Where permitted, our destruction methods may include irreversible de-identification or overwriting. We may keep archive copies of Personal Information and Student Data needed for audit, dispute resolution or legal compliance purposes, to the extent permitted by law.	We do not share any information with third party software or services unless we have your express consent or we are required by law to do so. In some cases we may use integrated Single Sign-On (SSO) such as Clever.com, however, personal information about students does not get shared with the SSO, nor do we receive personal information from the SSO. For integrated schools, we receive data directly from districts that are authorized to share the appropriate data so that students and teachers may access our products and use them to full effect. For non-integrated schools, we generate a class code for the teacher and their students to access the platform. We will never sell any of your information to other companies. We do not share information with other companies for the purpose of marketing. We will not disclose any of your personal information, except when we have your permission or under special circumstances, such as when we believe in good faith that disclosure is reasonably necessary to cooperate with local, state and/or federal law enforcement authorities, to enforce the Terms of Use or prevent unauthorized use of the Application, to respond to claims that any content in our applications violates the rights of third parties, or to protect the rights, property, or personal safety of Study Social LLC, its users, or the public. For purposes of the CCPA, in furnishing the Products to Education Customers, Accelerate Learning functions as a “service provider” and only processes “personal information” on behalf of its Education Customers for their business purposes. Accelerate Learning does not sell any “personal information” that is collected from Education Customers, students, or other users through or in connection with the Products. Accordingly, to exercise CCPA rights to know, delete or opt-out of sales of “personal information”, consumers are directed to contact their school, school district or other local educational agency who control the collection and use of “personal information” as the “business” under the CCPA, as noted above.	Terms of Service Privacy Policy
Membean	Information You Share Name, email address and other contact information: We ask for and collect personal information - at your discretion - when you submit web forms on our Websites, including opportunities to attend Membean sponsored events, to sign up for newsletters, to set up demos and pilots, to request customer support, to sign up to participate in a promotion, sweepstake or survey, or otherwise to communicate with us. Account Information: You may also optionally provide us with payment information if you decide to continue with a paid subscription to our Service. When we collect your payment information we will ask for your billing address, although we do not store full credit card numbers. Information We Receive Cookies: A cookie is a small text file stored on the user's hard drive for an extended period of time. You can control the use of cookies and their removal by configuring your Internet browser's privacy settings. Allowing a Membean cookie to remain on your computer makes it easier for you to log in to and use the Website. Note that if you disable cookies entirely, Membean Websites may not function properly. Log Files: We receive and log information when you interact with our Services, such as visiting the Websites, signing into your account or interacting with email notifications. Log data may include IP address, browser type, platform type, internet service provider (ISP), referring/exit pages, user identifiers, session identifiers, date/time stamp. We use this information for operating and improving our Services and to ensure secure, reliable and robust performance. For example, we use Log data to troubleshoot network issues, investigate application errors and ensure service integrity. Analytics: In conjunction with cookies and in addition to log files, we collect and record usage data to perform web application analytics, including pages visited, links clicked, mouse movements and non-sensitive form text entries. We use this information to better understand site usage, enhance customer support and improve user productivity. Profile: In order to provide personalized learning and progress assessments, we create a profile detailing usage and interactions. This profile is used solely for internal purposes and to help us improve the Services. We do not share your profile with any third parties. Affiliation: We may receive information about you from our business partners, including your email address and organizational role. We follow all applicable use and consent guidelines regarding the use of this information. Facilitation: Your school, school district, parent or legal guardian (each, an "Account Creator") may provide information about you to facilitate evaluation and onboarding of the Service at your organization. This may include name, address, school or school district information, email address, student names and school identification numbers ("Student Information"). Personal Information of Children Membean complies with the requirements of the Children's Online Privacy Protection Act (COPPA) and the FTC's Rule interpreting COPPA (16 CFR § 512) and the EU's (GDPR). If you are located in the United States and are under the age of thirteen (13) you must have your parent's or legal guardian's approval prior to posting any content on the Website. This is either obtained through your school or school district administrator or directly from your parents or legal guardian. If you are located outside the United States and are under the age of sixteen (16), depending on your location, you may need to obtain your parent's or legal guardian's approval prior to posting any content on the Website or otherwise using the Services. Membean collects limited personal information from students, including the Student Information described above ("Children's Personal Information"), but only where that student's school, school district, parent and/or legal guardian has contracted with Membean to collect Children's Personal Information from students for the use and benefit of the learning environment. Membean requires schools and school districts to obtain consent from students' parents and/or legal guardians before collecting any such Children's Personal Information. If you are a student, please do not send any Children's Personal Information about yourself to us, other than what we request from you when you sign up for Membean Services. In the event that we learn that we have collected Children's Personal Information from a student without parental consent being obtained, or if we learn a student has provided us Children's Personal Information beyond what we request when they sign up for Membean Services, we will delete that information as quickly as possible. If you believe that a student may have provided us Children's Personal Information beyond what is requested when signing up for Membean Services, or that parental consent has not been obtained, please contact us.	If your personally identifiable information changes, you may contact us to correct, update or delete and deactivate our record of your personally identifiable information. Parents and/or legal guardians may access their child’s information to correct, update, request deletion or further collection and use of their information, including Children’s Personal Information, by contacting us at the email address provided below or by contacting their school or school district administrator. All email communications sent by Membean include an "unsubscribe" link located at the bottom of such emails. Additionally, you may manage your preferences through account settings via the Website.	Service Providers: We engage other companies to help us perform functions and provide services ("Service Providers"). For example, Service Providers help us host Website content, operate our Services, monitor our performance, provide customer support, process credit card payments, manage and contact our customers, follow up on sales leads and enquiries and otherwise improve our Services. These Service Providers may only process personal information subject to our instructions and in compliance with this Policy, as well as obligations consistent with applicable confidentiality and security measures and regulations, including the GDPR. Business Transitions: We may share your information in the event that Membean goes through a business transition, such as a merger, acquisition by another company, or sale of a portion of its assets, as our customers' personal information may be part of the assets transferred. Customers will be notified via prominent notice on our Website prior to a change of ownership or control of their personal information. If, as a result of the business transaction, your personally identifiable information will be used in a manner materially different from that stated at the time of collection, you will be given a choice consistent with our Notification of Changes section. Required by Law: We will disclose personal information when required by law, or if we have good-faith belief that such action is necessary to (a) comply with current judicial proceedings, a court order or legal process served on us, (b) protect and defend our rights, or (c) protect the rights, property, and other interests of our users or others.	Terms of Service Privacy Policy
Mindplay	We collect and process information including personal information for our internal and Service-related purposes. Account registrations. When you register for an account, we collect personal identifiers (such as your name, username, mailing address, email address, and telephone number), educational institution-related information (such as your title, the educational institution name, district, and address, and the administrator’s name, title, email, and telephone number), the subscription(s) you purchased, your payment information including payment cardholder data, and any related details you submit through the Service. We use that information for account administration, security, order fulfillment, and marketing purposes. We also collect students’ personal information that you provide when you add a student to the account, such as the students’ personal identifiers (such as their name or identification number) and education-related information (such as their grade).	As a general matter, we only keep information for as long as necessary to fulfill the purposes for which it was collected and as permitted or required by law, including as necessary to comply with recordkeeping and legal obligations. Residual copies of this information may remain within our backup files, databases, and other records, and such copies are handled in keeping with our record retention procedures.	We may share any of the categories of personal information listed above for our business purposes as described below to assist us in providing products and services to you, including processing transactions, delivering products at your request, or helping us market to consumers. Educational Institutions. We share information, including personal information of students, with and as directed by educational institutions, including their authorized teachers, in connection with providing the Service. Affiliates. We share information, including personal information, with our affiliates, and any successors thereto in the normal course of our business operations, such as to communicate with you and to promote and provide our services. In this regard, personal information may be shared with one of our affiliates for use in providing a service to us. Vendors and service providers. We share information, including personal information, with vendors and service providers that process such information to perform services for us in connection with the Service or our other business operations. For example, if you purchase a subscription, we provide your payment card information to our trusted payment card processor. We also may access, preserve, and disclose the information if we believe that such action is necessary in our judgment to comply with a legal obligation or to protect and defend our rights or property, or those of others. For example, we may provide information, including IP address information, to our service providers to protect the Service, such as for fraud detection purposes. Legal and similar disclosures. We may share personal information with law enforcement, the courts, our advisors, attorneys, and others who participate in the legal process, if we believe doing so is required or appropriate to: comply with legal requirements and law enforcement requests (such as a court order or subpoena); comply with legal process (such as discovery); or protect your, our, or others’ rights, property, or safety. Other sharing. We may share information as described under “Information Collection and Processing” above and for other business purposes as otherwise explained in this Privacy Policy. Merger, sale, or other asset transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your personal information may be shared with the other parties and advisors involved under an obligation of confidentiality in connection with the negotiation of such transaction, and your personal information may be sold or transferred as part of such a transaction to the other parties. Any such sale or transfer shall be on the condition that your personal information continues to be treated in material compliance with this Privacy Policy. 3. DO-NOT-SELL DISCLOSURE We do not sell your personal information for money or other consideration. We also do not rent, sell, or share “personal information” as defined by California Civil Code §1798.83 about you that we collect on the Service with other people or unaffiliated companies for their marketing purposes.	Terms of Service Privacy Policy
Nearpod	When you access or use the Website, we may collect two types of information: (1) personally identifiable information; and (2) information that is not personally identifiable. Personally identifiable information includes information that identifies you personally, alone or in combination with other information available to us. Examples of personally identifiable information may include an individual’s name, address, telephone number, email address, and school or district information. As part of the standard operation of the Website, you may submit personally identifiable information. For example, when you create an account, you may provide personally identifiable information. In addition, should you attempt to communicate with Renaissance via the Website, email, phone, or response cards, you may provide us with personally identifiable information, and we may keep your message, email address, contact information, and other personally identifiable information. At your option, you may provide additional personally identifiable information about yourself. When you visit the Website, however, you are not required to create an account with the Website or provide any personally identifiable information. As part of the standard operation of the Website, we also collect non-personal information from you, including your browser type, operating system, IP address and the domain name from which you accessed the Website. In addition, we may collect information about your browsing behavior, such as the date and time you visit the Website, the areas or pages of the Website that you visit, the amount of time you spend viewing the Website, the number of times you return to the Website, the referring web page, pages visited, location, your mobile carrier, device and application ID’s and other click-stream data. We use a variety of third-party service providers to help provide the Website and to help us understand the use of the Website. These third-party service providers may use cookies, web beacons or similar technologies to collect information sent by your browser as part of a web page request, such as your IP address.	We have the right, but not the obligation, to: (1) retain your personally identifiable information for as long as your account is active or as needed to provide you services or access to or use of the Website; and (2) retain and use your personally identifiable information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements. We have the right, but not the obligation, to retain your non-personal information whether your account is active, inactive, or deactivated.	Renaissance does not rent or sell personally identifiable information and non-personally identifiable information to other companies. Instead, we use information collected via the Website in the following ways: ? Contact you when necessary; ? Respond to you regarding information you have requested; ? Communicate with you regarding Renaissance or the Website; ? Provide you with customized content and advertising for various products or services; ? Administer the Website, monitor its usage, and diagnose problems with it; ? Remember you when you return to the Website, so that you don’t have to re-submit information and preferences; ? Contact you with information and promotional materials and offers from us as well as from our affiliates, partners and other third parties, if you have agreed to receive such communications; ? Conduct research to improve our content and services; and ? To protect the security or integrity of the Website and our business. In addition to the examples above, Renaissance may use third-party storage, analytics, credit card processing companies, hosting companies, email service providers, marketing service providers, or Internet service-provider companies to perform some functions including the processing of data. Renaissance may also disclose information to protect our rights or property, to enforce our terms of use and legal notices, as required or permitted by law, or at the request of government regulators or other law enforcement officials and the courts (including the issuance of a valid subpoena). We shall have no duty to notify you of such compliance with the law. Renaissance may sell, transfer, or otherwise share some or all of its assets, including your personally identifiable information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy. We have the right, but not the obligation, to: (1) retain your personally identifiable information for as long as your account is active or as needed to provide you services or access to or use of the Website; and (2) retain and use your personally identifiable information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements. We have the right, but not the obligation, to retain your non-personal information whether your account is active, inactive, or deactivated.	Terms of Service Privacy Policy
Newsela	We collect Personal Information about you when you voluntarily submit information directly to us by accessing, using or receiving the Services. We may also collect Personal Information from third parties, such as from Schools, service providers, public databases, business partners or affiliates, social media networks and/or through the use of cookies and other technologies. For further information on your choices regarding your Personal Information, see the “Personal Information Preferences & Control” section below. a. Information we collect directly from you or from your school Personal Information we collect from you or from your School may include: Full Name and Contact information, including email address and mailing address Payment information (if applicable) Demographic data User content, feedback, assignments and annotation files, such as content provided by students and content provided by teachers and administrators relating to students School, grade, and classroom affiliation Birthdate Account information Access and usage data about your use of the features and functionality of the Services Login information such as username and password Information provided in response to surveys and promotions we make available to you b. Information we collect from third parties Single Sign On: You may choose to access, use or receive the Services by logging on or otherwise associating with another third party (for example, a Google, Microsoft or Clever account). In such instances, we may receive Personal Information from that third party to make it easier for you to create an account on the Services and display relevant content, such as your name, username, email address, language preference, or profile picture. The amount and type of Personal Information we collect from such third parties may depend on the privacy settings you or your School(s) have with that third party. Please consult the third party’s privacy policy and data practices for additional information. Information from Other Sources: We may obtain information from other sources, including through our service providers, affiliates, third-party information providers, business partners, or through transactions such as mergers and acquisitions. We may combine this information with other information we collect from or about you. In these cases, our Policy governs the handling of the combined Personal Information. We use this information to operate, maintain, and provide to you the features and functionality of the Services, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you. We may also collect information about you that is publicly available. When we provide our Services to Schools, some of the above information is directly related to an identifiable student and is maintained by the School or related entity or organization, or by us on behalf of such entity. This Policy refers to that type of information as “Student Data.” Student Data may include “educational records” as defined by the Family Educational Rights and Privacy Act (“FERPA”), 20 U.S.C. § 1232(g). For more information about ways in which we collect, use and process Student Data, please also see the Privacy Disclosures for Children and Students. c. Information we collect automatically when you use the Services We and our third-party service providers may automatically collect information about you and your computer or mobile device when you access, use or receive our Services, by using certain technologies that are further described below. These technologies help us learn more about how our users like to engage with our Services and help us improve our offerings and the functionality of our Services. These technologies may include: Cookies Unique Identifiers Web Beacons Analytics technologies Mobile device identifiers For more information about our use of Cookies and the other technologies described above, please refer to our Cookie Policy. Student Data we collect Includes: Contact Information School, grade, and classroom affiliation Birthdate Account Information Access and usage data about students’ use of the features and functionality of the Services Login Information Messages and user content Feedback provided by students Information provided in response to surveys and promotions we make available to students (if any) Student Data may include “educational records” as defined by the Family Educational Rights and Privacy Act (“FERPA”), 20 U.S.C. § 1232(g).	We do not knowingly retain Student Data beyond the time period necessary to support the School’s educational purpose. We do not delete or de-identify any Student Data from an active student user account associated with a School except at the direction of the School. Please note: Schools are responsible for maintaining current student rosters and identifying Student Data which the School no longer needs for an educational purpose by submitting a deletion request. School users may contact us at privacy@newsela.com to request deletion of Student Data. Even if we do not receive a deletion request from a School, we may delete or de-identify Student Data after a period of inactivity in accordance with our standard data retention practices. We may not be able to immediately or completely delete all data in all instances, such as information retained in technical support records, customer service records, backups, and other similar business records. We do not delete information which has been de-identified or disassociated with personal identifiers such that the remaining information cannot reasonably be used to identify a particular individual. We will also not delete any Student Data that has been transferred or stored in a personal account except at the request of the parent or student.	In accordance with how we use your Personal Information, we may share your Personal Information with the following: Other Users of the Services. Other registered users of our Services such as teachers or administrators may be able to see your profile information (e.g., username, profile photo, title and other employment- or education-related information and content, and other preferences and information), view the information and other content you provide, and communicate with you within the Services. Some of your data that is visible to others is dependent upon your privacy settings. For more information, please see the “Personal Information Preferences & Control” section. Schools, District Administrators, and Teachers. Schools, district administrators and teachers so they can engage with our Services, understand and grade student performances, and tailor content and materials for continued use. For example, we may share your Personal Information with new teachers who use the Services in their classrooms when you enroll in such teachers’ classes, and we may share teacher Personal Information with other teachers within a School using the Services. Service providers and advisors. Third party vendors, independent contractors, and other service providers that perform services for us, on our behalf, which may include providing mailing or email services, tax and accounting services, payments processing, data enhancement services, fraud prevention, web hosting, or providing analytic services. Affiliates. Other affiliates of Newsela, Inc. so that they can improve our Services, and provide you with updates, information and marketing messages about products or services that may interest you. The public. When you use our Services or engage with us on our social media platforms, content and information that you post on message boards, blogs or posts, or that you allow us to make public, may be available to other visitors to our Services and to the general public. Social Media Networks When you use our Services content that you share through social media may be shared with your social media account provider and your friends, followers or contacts on the connected social network. Law enforcement, regulators and other parties for legal reasons. Third parties as required by law or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) comply with legal process; (c) respond to requests from public or government authorities, including public or government authorities outside your country of residence; (d) enforce the terms of our agreement (being, as applicable, our Terms of Use Agreement for Public Services) and pursue available remedies or limit the damages that we might sustain; and/or (e) exercise or protect our rights, privacy, safety or that of our affiliates, clients, you or others. We may also disclose Personal Information to governmental regulatory authorities as required by law, including for tax or accounting purposes, in response to their requests for such information or to assist in investigations. Merger or Acquisition In connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets to another company, in which case the company receiving the Personal Information would be obligated to follow this Policy. Consent. We may disclose Personal Information with any other entity disclosed to you at the time we collect your information or with your consent or at your direction. We do not sell your Personal Information. For clarity, we may make recommendations within or through the Services of features, tools, and content on the Services to students based on their demographic information or activities on our Services. For example, we may suggest reading materials to a student based on the student having read a similar material in the past or based on the student’s age or grade level. We may also share information with others in de-identified, aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual. We disclose Student Data solely as needed to provide the Services on behalf of specific Schools in accordance with our contractual agreements with those Schools. Please note that Student Data and teacher account usage data may be disclosed to or accessible by users who are authorized to use the Services on behalf of the School. Student Data may also be accessible to anyone who accesses your account with your login credentials. To avoid unauthorized access to Student Data, please do not distribute your login credentials and keep all login information secure. In addition, depending on the manner in which the Services is used by the School and the terms of the agreement between the School and Newsela, we may provide access to certain Student Data to the student and/or to the parent or guardian of the student about whom the records relate, for the purpose of monitoring student usage and activity and evaluating the effectiveness of the School’s use of the Services. We also disclose Student Data to our trusted service providers who have a legitimate need to access such information on our behalf, subject to appropriate contractual terms to protect such data. Furthermore, we may disclose Student Data in connection with a business transaction or to support our legal rights and obligations, as described under the section entitled “Recipients of Personal Information” above. g. How We Use De-Identified Student Data We may collect and use De-Identified Data to operate, analyze, improve, market or develop educational sites, services or applications, to recommend content or services relating to school or educational purposes, and to demonstrate the effectiveness of our products or services. De-Identified Data means data from which all personally identifiable information, including direct and indirect identifiers, has been permanently removed or obscured so that the remaining information does not reasonably identify an individual and there is no reasonable basis to believe that the information can be used to identify an individual. If we share or publicly disclose De-Identified Data, that data will be aggregated or anonymized to reasonably avoid identification of a specific School or individual student.	Terms of Service Privacy Policy
No Tears Learning	[Basically, we collect data to help us provide you with cool technologies. We want to be open with you about that, so read this section.] In order to enhance our website and Services, we may collect the following types of information: Information About Educational Organizations. We ask for certain information about you or your organization when you register with us to use our Services, including school or organization name, teacher name, teacher information. Once you or your organization begins using our Services, we will keep records of activities related to the Service. We use this information to operate, maintain, and enhance the features and functionality of the Services, to analyze our Service offerings and functionality, and to communicate with you or your organization. Student Data. Learning Without Tears may have access to personally identifiable information and other non-public information about students as well as student-generated content and metadata (“Student Data”) in the course of providing its services to you or your organization. You or your organizations own the Student Data. We collect the following information about End Users in order to properly allocate licenses for and grant access to our Services: name, grade level, gender. We consider Student Data to be confidential and do not use such data for any purpose other than to provide the services to you or your organization. Learning Without Tears has access to Student Data only as requested by you or your organization and only for the purposes of performing services for you or your organization. Information Collected Through Technology. We automatically collect certain types of usage information when visitors view our website or use our service. We may send one or more cookies — a small text file containing a string of alphanumeric characters — to your computer that uniquely identifies your browser and helps to log you in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click and other actions you take on the Service), and allow us to track your usage of the Service over time. We may collect log file information from your browser or mobile device each time you access the Service. Log file information may include anonymous information such as your web request, Internet Protocol (“IP”) address, browser type, information about your mobile device, number of clicks and how you interact with links on the Service, pages viewed, and other such information. We may employ clear gifs (also known as web beacons) which are used to anonymously track the online usage patterns of our Users. In addition, we may also use clear gifs in HTML-based emails sent to our Schools to track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Service. We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Service. We do not allow third party advertising networks to collect information about the users of our Site or Service. We use or may use the data collected through cookies, log files, device identifiers, and clear gifs information to: (a) remember information so that a user will not have to re-enter it during subsequent visits; (b) provide custom, personalized content and information; (c) to provide and monitor the effectiveness of our Service; (d) monitor aggregate metrics such as total number of visitors, traffic, and usage on our website and our Service; (e) diagnose or fix technology problems; and (f) help users efficiently access information after signing in. Data De-Identification. We may de-identify and use de-identified Student Data for product development, research, or other purposes. De-identified data will have all direct and indirect personal identifiers removed. This includes, but is not limited to, name and ID numbers associated with an End User or Educational Organization. Furthermore, Learning Without Tears will not attempt to re-identify de-identified data or attempt to transfer de-identified data to any party unless that party agrees to not attempt re-identification. To be clear, we only collect and use data as necessary to fulfill our duties with respect to the Services we provide you or your organization.	We will ensure that all data associated with your licensed accounts that is in our possession is destroyed or transferred to you or your organization under the direction of you or your organization when the data is no longer needed for its specified purpose, at your or your organization’s request.	Basically, we don’t share any data unless required to by law or as a part of our internal business processes.] Learning Without Tears does not share Student Data with third-parties nor do we rent or sell any data or information for marketing purposes or to any third-party advertising networks. Learning Without Tears only shares Student Data in two limited circumstances. First, we may share Student Data with those who provide us technology services (e.g. web hosting and analytics services) but strictly for the purpose of carrying out their work for us to enable us to provide Services to you or your organization. Second, we may be required to share information with law enforcement or other third parties when compelled to do so by court order or other legal process, to comply with statutes or regulations, to enforce our Terms of Service, or if we believe in good faith that the disclosure is necessary to protect the rights, property or personal safety of our users.	Terms of Service Privacy Policy
Powerschool	B. CUSTOMER DATA PowerSchool customers are mainly K through 12 schools and districts, and higher education institutions. The makeup of Customer Data processed by PowerSchool can vary by PowerSchool service and a customer’s product configuration. PowerSchool provides a full spectrum of education-related services for customers to choose from. These include K-12 education technology products, higher education products, and administration products. Customers may have one or more of these PowerSchool products and services. Depending on the product or service, Customers may provide student data, employee data, or applicant data for PowerSchool processing. The mix of data provided by each customer may also vary based on how the customer configures the PowerSchool product or service for Customer Data collection (potential variations are discussed in more detail below). For this reason, it is impossible for PowerSchool to fully document the data that it will process for each customer until after the customer has fully implemented and configured the PowerSchool product and service. The configuration may also be dynamic in that the school or district may change its data collection configuration over time. If you have questions about which data is being collected by a customer connected to you, you should direct those questions directly to the PowerSchool customer that controls your data. The customer’s privacy policy may be another good source of information.When does a customer’s privacy policy govern?? PowerSchool’s Privacy Statement does not supersede the terms of any consent form, privacy notice or privacy statement from your school, school district or higher education institution, or stated alternatively, the terms of any agreements between you and your school or school district, or higher education institution (our customers). Who Owns Student Data Provided to PowerSchool by Customers for Processing??Student data is synonymous with Customer Data under this Privacy Statement. Accordingly, all Customer Data is owned, and thereby controlled, by our customers (school, school districts or higher education institutions). If required under applicable law, our customers are responsible for obtaining consent for PowerSchool to process Customer Data. For Customer Data processing under FERPA, the Family Educational Rights and Privacy Act, a United States federal law governing access to educational information and records, the customer designates PowerSchool as a “school official” with a legitimate educational purpose. Our customers license PowerSchool Products and purchase certain professional services for the purpose of providing, maintaining, and supporting student data for those legitimate educational purposes. PowerSchool will only process student data for the purposes of providing access to the PowerSchool Products and professional services that our customers (school or school districts) have contracted with us to provide, and we will process such student data according to instructions and the terms of our contract and data privacy agreements with our customers.?Many school districts are also obligated to parents to post information about the data that it collects. It bears mentioning again that PowerSchool processes the Customer Data under strict contractual obligations and privacy agreements signed with the customer. PowerSchool does not use or disclose Customer Data except as authorized and required by our customers and as provided for in our agreements with our customers. Because PowerSchool does not own or control Customer Data, any request for access, review, correction, or deletion of Customer Data must come directly from our customers.?With our customer’s consent, PowerSchool may receive information from affiliates in our PowerSchool Group of companies, or third parties and combine that information with Customer Data. C. COLLECTED DATA Although most PowerSchool on-line services and products are used by customers for Customer Data collection, PowerSchool websites and some PowerSchool products and services collect data directly from users of our website or those products and services. In these situations, PowerSchool is a “data controller” because PowerSchool determines the purposes for which and the manner in which personal information is processed. Because PowerSchool is the collector and controls the configuration of these products and services, PowerSchool can provide more detail on the data collection. These websites, products and services are further detailed below.We also collect device and usage information when you access and use the PowerSchool Products, including information that your browser or the mobile app sends when you are using our products. This data may include your unique device identifier, IP address, your browser type and configuration, the date and time of your use of the product or service and cookie data. Learn more about our use of cookies in our?Cookie Statement. D. TRANSACTION DATA Transaction Data is not Customer Data, nor is it Collected Data. It is a different PowerSchool category of data. Transaction Data may contain copied elements from Customer Data or Collected Data. For example, the logging of a user session may contain a unique id that identifies the user. The unique id is necessary for monitoring the health and security of PowerSchool applications.The monitoring of PowerSchool systems and applications is a part of our standard business operations to protect Customer Data and Collected Data; comply with laws; be able to provide customer support, and monitor events related to Customer Data or Collected Data. The monitoring of events is essential in preventing data-related incidents and determining if a data-related incident has occurred or is occurring that requires immediate attention by PowerSchool’s Incident Response Team. System and application events are monitored by the creation of artifacts or metadata about our systems, applications and their use. We call this “Transaction Data”. Transaction Data is vital to our ability to improve our products; trouble shoot customer support questions; analyze the health and performance of our products; and maintain security of Customer Data and Collected data, and privacy investigations. Transaction Data may either contain personal information along with application data that does not directly or indirectly relate to a person; or application data without any personal information at all.The storage and maintenance of Transaction Data is separate from the storage and maintenance of Customer Data and Collected Data with clear boundaries between the three types of data. In fact, Transaction Data is temporary. This means Transaction Data is permanently deleted on a regular rolling basis over time. This occurs regardless of whether Transaction Data contains any personal information or not. This is an implementation of the data minimization principle. Transaction Data which contains no personal information or Transaction Data containing even one element of personal information are all treated the same. Except for Service Providers acting as data subprocessors supporting our applications who are granted secure access to Transaction Data, PowerSchool does not share, disclose, sell or transfer such Transaction Data. Additionally, PowerSchool treats all Transaction Data as PowerSchool Restricted Information – meaning confidential and secured – and at the same level as Customer Data and Collected Data.PowerSchool does work with various data subprocessors to support the operability of our products. In order for these vendors to service us as captured in our agreements with them, they do create metadata within their systems. In these cases, PowerSchool binds these vendors to privacy requirements to ensure any metadata is properly deleted as required by law.PowerSchool respects our customers’ privacy and data security requirements. Transaction Data is one way we fulfill that promise to our customers – educational institutions and individuals. Transaction Data provides us with the ability to service our customers properly. F. CHILDREN’S PRIVACY Under the Family Educational Rights and Privacy Act (FERPA), PowerSchool acts as a “school official” with “legitimate educational interests” and contractually relies on educational institutions to obtain parental consent, if required. More generally, PowerSchool has processes and procedures in place to protect the personal information of children under 13, as detailed below. We do not use such information for any purpose other than to provide our services and for the specific uses set forth below, in accordance with contractual agreements with our customers and our Terms of Service. In addition, PowerSchool’s Schoology Basic product, our free publicly accessible version of Unified Classroom® Schoology Learning, received a PRIVO Kids Privacy Assured Children’s Online Privacy Protection Act (“COPPA”) Safe Harbor certification starting in 2016. PowerSchool has established COPPA-compliant privacy practices and has agreed to submit to PRIVO’s oversight and consumer dispute resolution process. These practices impact the development and implementation of other PowerSchool Products other than Schoology Basic. Consent to Collect, Use, or Disclose Personally Identifiable Information from Children Under 13. Children under 13 may only use PowerSchool’s Products with the prior consent of a parent or educational institution acting on behalf of the child’s parent. We will not collect, use, or disclose any personally identifiable information from children under 13 without such consent. Educational institutions may consent to the collection, use, or disclosure of personally identifiable information from children under 13 by agreeing to purchase our products. Personal Information from Children Under 13 Provided to PowerSchool. PowerSchool products may collect the following categories of personal information from children under 13, with the appropriate consent: Information provided via customers or through use of PowerSchool’s Products, assessment data, conduct or behavior data, demographic data, enrollment data, contact information, course schedule data, online communications, student identifiers (e.g., school ID number), academic or extracurricular program membership, student-generated content, transcript data, college interests, college application list, college scholarships, career interests, and post-secondary planning data; and Usage, browser and device information. PowerSchool does not allow personal information from children under 13 to be made publicly available via its Products. PowerSchool does not share personal information from children under 13 with third parties unless consented to under our customer agreements or necessary under the law. Service providers, partners, and product integrations. Our service providers help us with things like data security, cloud hosting, information technology, customer support, usage and analytics, email delivery, application performance monitoring, and user identity and authentication. In addition, some of our Products may support partnerships and integrations that offer certain features to users, like CommonApp, Gallup, and McGraw-Hill Education, at the election of educational institutions (see further detail in Section IV). Administrative and legal reasons. When reasonably necessary to meet and comply with any applicable law, regulation, legal process or enforceable governmental request; enforce applicable Terms of Service, including investigation of potential violations; detect, prevent, or otherwise address fraud, security or technical issues; or protect against harm to the rights, property or safety of PowerSchool, our users or the public as required or permitted by law. Business transitions. In the event that PowerSchool goes through a business transition such as a merger, acquisition by another company, sale of all or a portion of its assets, bankruptcy, or other corporate change (including during the course of any due diligence process), this personal information may shared or transferred based on consent of our customers. Our customers, educational institutions, may share personal information of students with educators as needed for educational purposes. PowerSchool does not control and is not responsible for this type of sharing. If you are a parent and have questions about this, please contact your child’s educational institution. PowerSchool does not share personally identifiable information from children under 13 for advertising or marketing purposes. Parental Rights. For PowerSchool Products provided to educational institutions, the collection, maintenance, and use of personal information from children under 13 is controlled by the educational institution that contracts with PowerSchool for use of its Products. If you are a parent and have questions regarding personally identifiable information collected from your child as part of their educational institution’s use of PowerSchool’s Products, including your rights to review, delete, and refuse further collection of such information from your child, please contact your child’s educational institution. PowerSchool cannot delete such information unless authorized by your child’s educational institution.	We keep information collected on behalf of our Customers for as long as necessary to fulfill the purpose for which it was collected, pursuant to contractual terms or as otherwise required by applicable law. We dispose of information that is not held pursuant to contractual terms within a commercially reasonable time period or at the request of a customer using reasonable measures to protect against unauthorized access to or use of information	To comply with PowerSchool’s obligations under applicable data protection laws and to our customers, we provide a list of significant third-party suppliers that enable us to provide our products and services and operate our business. These third-party suppliers perform the functions described below and are considered subprocessors under applicable data protection laws (“Subprocessors”). We require our Subprocessors to implement proper security measures to safeguard and to respect the privacy rights attendant to Customer Data and Collected Data.	Terms of Service Privacy Statement
Readworks	When you visit and use our Site, we may collect information about you. Information you provide to us: In order to get access to certain information or materials that are provided through the Site, you may have to provide information to us. We collect and store this information in a way that allows us to connect it to you personally, including, for example, your name and email address. We refer to this information as personal information. Additionally, we may collect and retain a record of all communications we have with you. Information we collect through technology: We may also collect information about you through technology. For example, we may collect your IP address each time you click on a page during a visit to our Site. The Site may also use other technical methods to track and analyze website traffic patterns, such as how often our users visit different parts of the Site. These technical methods may involve the transmission of information either directly to us or to another party we have authorized to collect and process information on our behalf, such as Amazon Web Services. More information on how Amazon Web Services uses data can be found at https://aws.amazon.com/privacy/. We may also use technical methods in emails that we send educator or parent Site users to figure out if users have opened those emails and/or clicked on links in those emails. We may collect the information from these technical methods in a form that is personally identifiable.	None noted.	We do not disclose nonpublic personal information about users of the Site to any nonaffiliated third parties, except as described here or in our Terms of Use. We may use or disclose certain personal information we collect about our users when they visit and browse our Site as part of our normal operations, including through our promotional email platform, ActiveCampaign. We make every effort to segregate student data from that of educators, parents, and guardian users and do not share such data with ActiveCampaign. More information on how ActiveCampaign uses data can be found at https://www.activecampaign.com/legal/privacy-policy. We may also use or disclose certain personal information to respond to specific requests we get from you and through our use of service providers in connection with the Site. These third-party service providers may have access to and use your personal information, but only as needed to perform the functions we have asked them to perform. All third parties adhere to the same security and data retention principles as ReadWorks. ReadWorks only shares your personal information with third-party service providers that are consistent with our privacy policy. ReadWorks does not display any advertisements on our Site nor provide promotional sweepstakes or contests. There is no traditional, contextual, or behavioral advertising on the ReadWorks website. Users can opt out or unsubscribe from marketing communications by selecting the “Unsubscribe” button at the bottom of every email or emailing ReadWorks at help@readworks.org. When we believe we have to disclose something because it is required by law, regulation, legal process, subpoena, document, or governmental request, we will disclose personal information we collect from you. We may also do so to help enforce our Terms of Use, protect your safety or security, or protect the safety and security of tangible or intangible property that belongs to us, to you, or to third parties. We may transfer all user information (which may include personal information) to our acquirers or successors. Our acquirers and successors in the future will act in accordance with this privacy policy. Other than as part of such a transaction, we will not sell any of your personal information. Non-personal information is information that does not personally identify you, including anonymous information and aggregate data. We may use this information to understand better how our visitors use the Site, provide visitors with customized services and information, improve the Site, and for other similar purposes. We may combine this information with personal information. We may share this information with others and use this information in any manner permitted by law, but any disclosure that identifies you personally will be governed by the above paragraphs on personal information.	Terms of Service Privacy Policy
Renaissance Learning	What Personal Information do We collect? Information provided through use of the Products Renaissance only collects information from a Child that is reasonably necessary for the Child to use the Products for purposes authorized by a School. Schools creating a Child Account will provide the Personal Information described in Our Categories of Data Collected by Product overview. Once a Child Account is created, the data generated from a Child's use of Our Products 1s further described in Ow Categories of Data Collected by Product overview Information collected automatically • Usage information We and/or Our service [Jrov1ders may automatically collect certain ''Usage Information" whenever users, including Children, access and use the Products. For example, We may collect information regarding how often a user accesses certain features Usage Information may include the browser and operating system a user is using. all of the areas within Our Products t11at users visit, and the time of day they used the Products, among other information. We may Use usage information for a variety of purposes, including to select appropriate content to display to users and to enhance or otherwise improve the Products. • Device information. We and/or Our .SffY.!.ce p1 ovjde1 s may collect IP addresses or other unique identifiers ('Device Identifiers") for any computer, mobile phone or other device (any, a "Device") used to access the Products, including by Children. A Device Identifier is a number that is automatically assigned to the Device used to access the Products. and Our servers identify each individual's Device by its Device Identifier. Some mobile service providers may also provide Us or Our third-party service providers with information regarding the physical location of the Device used to access the Products, internet service provider (ISP), date and time of a user's visit, browser language, browser type, referring and exit pages and URLs, amount of time spent on particular pages, which parts of the Products they use, which links users click, search terms, operating system, traffic and related statistics, keywords, and/or other general browsing or Usage Information. The Products may also access files, including metadata, stored on a Device if a user chooses to send or provide access to Us. Information collected via cookies and other tracking technologies. We and/or Our service providers may Use ''cookies· (a small file sent to your computer by a Website or device to allow the Website or app to store information which uniquely identifies you) or other similar tecl1nology to collect data in order to assist Our users, including Children, and provide them with a more personal experience, to allow for the technical operation of the Products, to enhance the performance and functionality of the Products, and for analytics purposes. Users can disable cookies at their browser or device's settings, but in that case some (or all) of the features and functionality of the Products may not be available. We do .D.Q1 use cookies or any other tracking technologies to direct advertisements to Children.	Renaissance shall comply with its privacy and security obligations for Customer PII as set forth in the Data Protection Addendum. As between Renaissance and Customer, Customer owns the Customer Data. Customer grants Renaissance a non-exclusive, royalty-free, worldwide license to use the Customer Data throughout the Term to perform under the Agreement and as further described in the Data Protection Addendum. As between Renaissance and Customer, Renaissance owns the Renaissance Data. Renaissance Data is not subject to the use or disclosure restrictions of this Agreement that apply to Customer Data. Customer acknowledges and agrees that the Products are intended for academic, educational and assessment purposes. Customer shall not provide to Renaissance any non-academic or non-educational related data such as social security numbers, protected health information, driver's license information, password or visa numbers, credit card or other financial account numbers, and Renaissance has no obligation to monitor for entry of such data.	• With Schools and Educators We may share Personal Information of a Child with the Child's School and Educators of the Child's School. subject to the Te1rns of Se vice agreement between Renaissance and the relevant School. We do not control, and are not responsible for, Educators' handling of the Personal lnfo1mation of Children As noted above, if you are a Parent and have questions with respect to Personal Information that We process, please direct these questions to your School. • With service providers We may share Personal Information with service providers that help Us deliver the Products by offering hosting, information technology, customer support. data security, and consumer and educational research services. We also work with service providers to provide Us with analytics and other information regarding traffic on the Products, including the features used when visiting the Products and to provide Us with information regarding the use of the Products A list of our service providers is available HSRE. • For administrative. legal. and academic integrity reasons. We may disclose Personal Information in response to a subpoena, court order, o, when otherwise required by law, ,n response to bankruptcy proceedings; to defend our rights; in response to a request from law enforcement; to provide information to a claimed owner of intellectual property who claims that content a Child has provided to us infringes on their rights; upon request of or as otherwise authorized by an academic institution connected to an investigation into academic integrity; to protect and/or defend Our Terms of Service agreement or other policies applicable to the Products; or to protect the personal safety, rights, property or security of any organization or individual. We may also use Device Identifiers, including IP addresses, to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies in our discretion. These disclosures may be carried out without consent or without notice to users, Schools, or Parents. • For business transitions and operational purposes. We may share Personal Information with a parent entity, subsidiary, affiliate, or investor of Renaissance, as applicable, for lawful business and operational purposes. In the event that Renaissance goes through a business transition such as a merger, acquisition by another company, or sale of all or a portion of its assets, bankruptcy, or other corporate change (including, without limitation, during the course of any due diligence process), Personal Information will likely be among the assets shared and/or transferred	Terms of Service Privacy Policy
Rosetta Stone	Personal information is collected by Rosetta Stone. We collect personally identifiable information about you (your “Data”) through: ? The use of inquiry and registration forms. ? The purchase process when you buy any of our products or services ? The provision of your details to us either online or offline The elements of your Data that we collect may include: ? Name ? Job title ? Company name ? Home, shipping and billing addresses, phone and fax number ? Mobile telephone number ? E-mail address ? IP address and browser information ? Payment details such as credit card information ? Market research data such as customer usage patterns We do not intentionally collect any information on children under 13 years of age. We will undertake to delete any details of such users where a parent or guardian has notified us that any such details have been obtained.		We use the information you provide when placing an order to complete that order. We do not share this information with outside parties except 1. To the extent necessary to complete that order or to provide you with services by way of our service providers (e.g., payment processing, third-party shipping, business analytics, customer support), or 2. To successors in title to our business, or 3. In accordance with legal and regulatory requirements, or 4. As necessary, in Rosetta Stone’s sole discretion, to protect the perceived rights, safety and property of Rosetta Stone, users of our websites, and the public, or 5. With the parent organization, affiliate or subsidiary entities of Rosetta Stone to manage and control Data as joint users. Other than as set out above, you will be notified when Personal Information about you will be shared with third parties, and you will have an opportunity to choose not to have us share such information. We also use information in aggregate form (so that no individual user is identified): ? To build up marketing profiles ? To aid strategic development ? To audit usage of the site	Terms of Service Privacy Policy
Sadlier	When using the Site, in order to utilize some of the services, you may be asked to provide, or you may choose to upload, certain personally identifiable information about yourself ("Personal Information"). Personal Information can include your name, birth date/age, gender, email address, physical address, telephone number, billing and shipping information, position/title/subjects, school/parish, school grade, or other information you may provide. Similarly, when you post a photograph, enter or respond to a contest, survey, questionnaire, sweepstakes or other promotional feature, we may ask you for your name, address and email address or other personal information. We do not collect any Personal Information about you unless it is voluntarily provided by you. In addition, only people who are 13 or older may purchase products from our Site. In addition, we may also collect non-personally identifiable information, such as IP host address, pages viewed, browser type, duration and frequency of visits, and other data, and may aggregate any information collected in a manner which does not identify any individual ("Aggregate Information"). Information obtained in connection with the Site may be intermingled with and used by us in conjunction with information obtained through sources other than the Site, including both offline and online sources. This Site is not intended for persons under the age of 13, and we have no intention of collecting Personal Information from persons under the age of 13. Where appropriate, we take reasonable measures to inform children not to submit such information to our Site or in response to advertisements. If a child has provided us with personally identifiable information, we will use all reasonable efforts to delete such information from our database.	None listed.	We may use the Personal Information that we collect to help improve our Site, to process your orders/subscriptions/registrations, and to contact you about our products and services or those of our partners or other third parties from time to time. We do not sell your Personal Information to third parties or mass marketers. For example, we will not sell another company your name or email address. Unless you consent to the disclosure of your Personal Information, only we and our affiliates, our technical consultants, third party auditors and other third parties who make our Site available, enhance its functionality, assist with the processing of your purchases, or provide associated services and/or who deal with you in delivering content, samples, products, gifts and prizes, have access to this information, and we require them to agree that they are covered by this policy. Please note that Sadlier reserves the right to and may disclose Personal Information about you in response to (a) requests from local, state or federal law enforcement officials; (b) any judicial, administrative or similar proceeding or order, such as subpoena; (c) if required by law; or (d) to investigate suspected fraud, harassment, physical threats, or other violations of any law, rule or regulation, the Site rules or policies, or the rights of third parties or to investigate any suspected conduct which we deem improper. Please also note that we do reserve the right to transfer your personally identifiable information and other information to our successors in business and purchasers of Site assets.	Terms of Service Privacy Policy
Savvas Learning Company, LLC	We may request and store certain types of personally identifying information about you when you use this Site. We consider the following to be examples of personally identifying information: your first and last name, email address, home address, phone number, date of birth, social security number, credit card and banking information, and other similar information. We do not collect personally identifying information about you unless it is voluntarily provided and needed for the delivery of services you wish to use. It is your choice whether to share personally identifying information with us but please keep in mind that in some instances such information will be required in order to participate in activities within the Site. PLEASE NOTE THAT WE DO NOT CONSIDER ANY INFORMATION THAT IS NOT ASSOCIATED WITH YOUR PERSONALLY IDENTIFYING INFORMATION (ANONYMIZED OR AGGREGATED INFORMATION) TO BE PERSONALLY IDENTIFYING INFORMATION. The information we learn from you, including personally identifiable information, helps us personalize and continually improve your experience and use of this Site so that we can further serve your needs and our business needs. BY USING THE SITE, YOU ARE CONSENTING TO THESE USES AND OTHERS AS SPECIFIED HEREIN AND IN THE TERMS OF USE. When you conduct a purchase transaction through this Site, you are providing transaction information to our third-party suppliers (such as transaction processors and financial institutions) who will use the information solely for processing your requested transaction. There may also be other third-party vendors who supply software applications, web hosting and other technologies and/or services for this Site that may have access to your personally identifying information but, unless they get express permission from you, they will not use such information for any other purpose other than to provide services in connection with this Site. During your use of the Site you may generate or upload certain content (“User Content”) to the Site and we may store and link such User Content to your personally identifying information. In addition, either we or our third-party service providers may collect information about your usage of a respective service, time spent on a service, pages visited and detailed session data in connection with a specific service and other similar information (“Site Usage Information”). We may use this User Content and Site Usage Information in combination with your personally identifying information to customize your experience using the Site by, among other things, making recommendations or forecasts. We may also use your User Content and Site Usage Information to suggest other features on the Site that we believe may be interesting to you. Please refer to section below entitled “Cookies and Other Technology Used to Collect Information” for more information on the process and methodology of collecting and sharing certain Site Usage Information.	Applicable law in your jurisdiction may permit you to, among other things: (i) request certain details about what personal information is stored by us about you, or how that information may be shared with third parties for marketing purposes or otherwise, (ii) request that your personal information not be sold to third parties, or (iii) request that we delete your personal information. If you would like to make such a request under the laws of your jurisdiction, please contact us by clicking here.	We will not share any personally identifying information about you with any third party (a party not affiliated with us) except as otherwise stated herein and in the following circumstances: (i) in response to subpoenas, court orders or legal process, to the extent required and as restricted by law; (ii) when disclosure is required to maintain the security and integrity of this Site, or to protect any user’s security or the security of other persons, consistent with applicable laws; (iii) when disclosure is directed or consented to by the user who has inputted the personally-identifying information; (iv) in the event that we go through a business transition, such as a merger, divestiture, acquisition, liquidation or sale of all or a portion of its assets, your personal information will, in most instances, be part of the assets transferred; (v) in limited circumstances, we may disclose your email address in order to comply with laws and regulations, including the Controlling the Assault of Non-Solicited Pornography and Marketing Act (CAN-SPAM of 2003); (vi) to enforce the Terms of Use; or (vii) to third parties performing work for us under contract who have committed to protect the privacy of personally identifiable information in a manner consistent with this Privacy Statement.	Terms of Service Privacy Policy
Snap and Read	See Privacy Policy for extensive tables.	Data is stored on servers located in the United States. If you live outside of the United States and have laws governing data collection and use that differ from U.S. law, then you acknowledge and agree that you are transferring your Personal Information outside of those regions to the United States and that, by providing your Personal Information to Snap&Read Universal, you consent to that transfer. Some data is also stored locally on your computing device and synchronizes to our servers when an online connection is present. Data that syncs include Option Settings, Text saved in Outlines, Text saved in Sources; and if a user is a Student User: Readability of Text, approximate number of words read, number of words read using text to speech, and approximate time spent reading. All data stored on our servers is encrypted. All transmission of information is encrypted and protected using Secure Sockets Layer (SSL). Passwords are stored using a hash function. We also use physical, managerial, and technical safeguards to secure your data. In the event that your Personal Information may be compromised, we will attempt to notify you electronically so that you can take appropriate protective steps. If an account is terminated by an Educator, a Student may transfer their data by acquiring a Personal Account or by acquiring an activation code from another Educator.	Don Johnston Incorporated does not sell, share, rent or otherwise disclose your information collected by Snap&Read Universal. We do not use student information collected through our services for behavioral targeting or advertising or any commercial purpose. Information is only disclosed when: We have your explicit consent to share the information. It is required to comply with the law including compliance with warrants or court orders. It is required to protect the rights, property or personal safety of Don Johnston Incorporated and users of Snap&Read Universal We do not monitor or view any Personally Identifiable information or content stored in Snap&Read Universal.Below lists the limited circumstances where your information may be accessed by our employees. We need to do so in order to respond to your explicit request for support. Where necessary to protect the rights, property or personal safety of Don Johnston Incorporated and Snap&Read Universal’s users (including protection against potential spam, malware or other security concerns). We believe our Terms of Service has been violated and confirmation is required. Aggregate, non-identifiable information is solely used to enhance Snap&Read Universal and, in the case of anOrganizational Account, support implementation. We do not, under any circumstances, advertise to Student Users or Child Users. For Educator Users, Parent Users, and Personal Users, we practice permission marketing: you will only receive information from us when you give explicit consent in advance to receive the marketing information.	Terms of Service Privacy Policy
Studies Weekly	We only have access to and collect information that you voluntarily provide. We do not sell or share this information. Data provided by you or your organization (either through automated rostering or by interaction with user accounts) is and shall remain the property of the provider. All data released is in compliance with the Family Education Rights and Privacy Act (FERPA) and Studies Weekly policies as set forth in this document, as set forth in this document, for managing student education records and other confidential information. Partnering organizations grant Studies Weekly license to use such data for: Communication Shipping Creating accounts Identifying user access to their data Creating aggregate reports Data will not be divulged to unauthorized third parties or used in any way that would violate FERPA.	We may send emails to educators about promotions, new products, and services, but they may unsubscribe at any time. Although one may unsubscribe from all marketing emails, we reserve the right to contact any customer with product updates and other information that relates to purchases and subscriptions. Anyone may contact us to: See what data we may have about them Change or correct their data Ask us to delete their data Express concern about use of their data	We only have access to and collect information that you voluntarily provide. We do not sell or share this information. Data provided by you or your organization (either through automated rostering or by interaction with user accounts) is and shall remain the property of the provider. All data released is in compliance with the Family Education Rights and Privacy Act (FERPA) and Studies Weekly policies as set forth in this document, as set forth in this document, for managing student education records and other confidential information. Partnering organizations grant Studies Weekly license to use such data for: Communication Shipping Creating accounts Identifying user access to their data Creating aggregate reports Data will not be divulged to unauthorized third parties or used in any way that would violate FERPA.	Terms of Service Privacy Policy
SWI Photo	WHAT STUDENT PERSONAL DATA DO YOU COLLECT/RECEIVE FROM SCHOOLS? The information we need for Picture Day depends on the specific services SWI Photography is providing your school. We collect the basic information in advance of Picture Day in order to match names to the pictures and for efficient distribution within the school. We may receive your email or mailing address in order to deliver Picture Day related communications on behalf of the school. In such cases, we do not retain or use your information for any other purpose. Schools and/or counties decide how much, or how little, information is used in producing School Photography Items. SWI never has access to sensitive information, such as grades or attendance data, from your child’s(s) record. CHILDREN’S POLICY We do not knowingly collect personal information from children under 13. We take children’s privacy seriously and encourage parents to play an active role in their children’s online experience at all times.	You can withdraw your consent to receive promotional communications from us at any time. If you choose not to provide us with the right to use personal information, we may not be able to provide you with the product, service or information you requested. You can use third party sites, services and apps to opt out of the collection of your information from certain third parties, such as Google and other third-party advertising service providers (if you clear your cookies, you’ll need to opt out again). You can also review and update your personal information in our possession. Please note that you cannot unsubscribe from certain correspondence from us, including messages relating to your transactions.	We use information we collect to communicate with you about our products or services; to manufacture and produce our products such as yearbooks; to process orders and support our commerce solutions; to provide, manage and improve our Properties, products, services and business; in connection with promotions such as sweepstakes and contests; for us and our service providers to provide services and deliver content; to comply with legal requirements and protect you, SWI Photography, and others; and in connection with corporate events such as a sale of the business. We use information provided by schools to provide our products and services and as otherwise allowed under this Policy except where a school has restricted our rights to use provided information, and we will not sell or rent such information to any third party. We share your personal information with certain partners if you have given us permission to share it with that partner. Except as prohibited by applicable law, we also use your information to personalize your user experience, to improve our Properties, products and services, for fraud prevention, to provide reporting, and for other historical, statistical or research and analysis purposes. If you are outside the US, you give us consent to transfer it to the US. We use your personal information to complete transactions, respond to your requests, deliver products and services you request, and send communications to you about promotions, updates, or special offers (which may be offered by SWI Photography or one of its business partners) that may be of interest to you. We may share your personal information with carefully selected vendors and business partners, including companies that perform marketing services and other business operations for us. We may also use your personal information to provide analyses of our users in the aggregate (including analytical data subject to the terms of this privacy policy) to prospective partners and other third parties. In addition, we will share the personal information we collect from you under the following circumstances: We will share personal information if we have a good faith belief that (i) access, use, preservation or disclosure of such information is reasonably necessary to satisfy any applicable law, regulation, legal process, such as a court order or subpoena, or a request by law enforcement or governmental authorities, (ii) such action is appropriate to enforce our Terms of Use for the SWI Photo Property, including any investigation of potential violations thereof, (iii) such action is necessary to detect, prevent, or otherwise address fraud, security or technical issues associated with the SWI Photo Process, or (iv) such action is appropriate to protect the rights, property or safety of SWI Photography, its employees, users of the SWI Photography Property or others. Service Providers. We may share your personal information with service providers that we engage for the purpose of processing information on our and your behalf. For example, we may partner with other companies to process payments for SWI Photography. Additionally, we may partner with other companies to process, analyze, and/or store data, including, but not limited to, Analytical Data. While providing services for us, these companies may access your personal information. To the extent applicable, we require these entities to comply with this Privacy Policy and appropriate confidentiality and security measures. This Privacy Policy does not cover the information practices of third-party websites linked to the Site. Although we encourage such third parties to adopt and follow their own privacy policies, we are not responsible for their collection and use of your personal information. You should refer to the privacy policies and statements of other websites or contact the respective webmasters of those websites to obtain information regarding their information collection, use, and disclosure policies. When you have clicked on a third party logo or URL displayed on our Site which links you to a different website, our Privacy Policy no longer applies and you must read the privacy policy of the third party to see how your personal information will be handled on their website.	Terms of Service Privacy Policy
Tools4Ever	We collect information from you when you subscribe to our newsletter or fill out a form. When ordering or registering on our site, as appropriate, you may be asked to enter your: name, e-mail address, mailing address, or phone number. You may, however, visit our site anonymously. Tools4ever has signed The Student Privacy Pledge to safeguard student privacy regarding the collection, maintenance, and use of student personal information. The Pledge outlines a dozen commitments to this effect. It was developed by FPF and SIIA in 2014 with guidance from school service providers, educator organizations, and other stakeholders following a convening by U.S. Representatives Jared Polis (CO) and Luke Messer (IN). The pledge has also been endorsed by the National PTA and the National School Boards Association, among others. Read the entire pledge.	We offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our Database. This data is only viewed by those authorized with special access rights in our systems, and who are required to keep the information confidential. After a transaction, your private information (credit cards, social security numbers, financials, etc.) will not be kept on file for more than 60 days.	We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. This does not include trusted third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.	Terms of Service Privacy Policy
Tyler Technologies	Except with respect to certain Tyler services provided to school and school district clients with whom Tyler has a contract, the Tyler Platform is not directed to persons under the age of sixteen (16), and we do not knowingly collect, request, or use personal information directly from children via the Tyler Platform, or offline. As noted above, except for services Tyler provides to school and school districts clients with whom Tyler has a contract to use the Tyler Platform, the Tyler Platform is not directed to persons under the age of sixteen (16). We do not knowingly collect, request, or use personal information of children via the Tyler Platform, or offline unless or until a Tyler school or school district customer had provided authorization for a student under the age of sixteen (16) to use the Tyler Platform. If we become aware that a child under 16 has provided us with personal information outside of the provision of the Tyler Platform to a school or school district customer, we will take steps to delete the information as soon as possible. If you believe that your child under the age of 16 has submitted personal information to Tyler, please contact us at privacystatement@tylertech.com.	We will retain your personal information for as long as the Tyler client for which we are providing services directs us to retain it or for the length of time needed to fulfill the purposes outlined in the section above titled, “Why We Process Your Personal Information,” unless a longer retention period is required or permitted by law.	We may share the personal information that we process on behalf of our clients with subprocessors or service providers who help us process your information for the provision of services we are contractually obligated to provide to our clients. We contractually require that our subprocessors comply with the legal obligations we have with respect to your personal information. We may share your information if we believe it’s necessary to comply with law or protect our users or employees. Third Parties:?We share information with our subprocessors or service providers that assist with the operation of the Tyler Platform and Tyler’s business operations that support tour provision of services to our clients more generally. We share information with third parties only as necessary for the third parties to provide the services to us.? Such third parties have an obligation to protect the information they receive from us or collect on our behalf and may use such information only for the purposes that we allow. Your information may also be collected and processed by other third parties, such as the payment providers you select when you purchase Tyler products or services, and who will process your information independently in accordance with their own privacy notices. Data Analytics Providers:?As noted above, Tyler partners with third parties to assist with performing business analytics. Tyler Affiliates or Successors: We may disclose personal information to and among our Tyler family of affiliated companies. In addition, we may share your information with an entity that succeeds to all or part of Tyler’s business in connection with a sale, reorganization, consolidation, or merger. Other Third Parties:? We and our third parties will disclose specific individual information if we or they reasonably believe it is necessary to: (i) comply with applicable law; (ii) protect or defend the rights, property and interests of Tyler, our employees, or the interests of our third party service providers and partners; or (iii) under exigent circumstances, to protect the personal safety of our users and clients, or the public.	Terms of Service Privacy Policy
William H. Sadlier, Inc	When using the Site, in order to utilize some of the services, you may be asked to provide, or you may choose to upload, certain personally identifiable information about yourself ("Personal Information"). Personal Information can include your name, birth date/age, gender, email address, physical address, telephone number, billing and shipping information, position/title/subjects, school/parish, school grade, or other information you may provide. Similarly, when you post a photograph, enter or respond to a contest, survey, questionnaire, sweepstakes or other promotional feature, we may ask you for your name, address and email address or other personal information. We do not collect any Personal Information about you unless it is voluntarily provided by you. In addition, only people who are 13 or older may purchase products from our Site. In addition, we may also collect non-personally identifiable information, such as IP host address, pages viewed, browser type, duration and frequency of visits, and other data, and may aggregate any information collected in a manner which does not identify any individual ("Aggregate Information"). Information obtained in connection with the Site may be intermingled with and used by us in conjunction with information obtained through sources other than the Site, including both offline and online sources. This Site is not intended for persons under the age of 13, and we have no intention of collecting Personal Information from persons under the age of 13. Where appropriate, we take reasonable measures to inform children not to submit such information to our Site or in response to advertisements. If a child has provided us with personally identifiable information, we will use all reasonable efforts to delete such information from our database.	Sadlier will not be liable for disclosures of your Personal Information due to errors in transmission or unauthorized acts of third parties. We have undertaken all commercially reasonable efforts to prevent unauthorized Internet access to visitor data retained in our servers, however, due to the inherent open nature of the Internet, Sadlier cannot ensure or warrant the security of any information you transmit to us or any information provided online, and you do so at your own risk. Users must accept all risks associated with any data transmission, including the risk that their personal information may be intercepted in transit.	We may use the Personal Information that we collect to help improve our Site, to process your orders/subscriptions/registrations, and to contact you about our products and services or those of our partners or other third parties from time to time. We do not sell your Personal Information to third parties or mass marketers. For example, we will not sell another company your name or email address. Unless you consent to the disclosure of your Personal Information, only we and our affiliates, our technical consultants, third party auditors and other third parties who make our Site available, enhance its functionality, assist with the processing of your purchases, or provide associated services and/or who deal with you in delivering content, samples, products, gifts and prizes, have access to this information, and we require them to agree that they are covered by this policy. Please note that Sadlier reserves the right to and may disclose Personal Information about you in response to (a) requests from local, state or federal law enforcement officials; (b) any judicial, administrative or similar proceeding or order, such as subpoena; (c) if required by law; or (d) to investigate suspected fraud, harassment, physical threats, or other violations of any law, rule or regulation, the Site rules or policies, or the rights of third parties or to investigate any suspected conduct which we deem improper. Please also note that we do reserve the right to transfer your personally identifiable information and other information to our successors in business and purchasers of Site assets.	Terms of Service Privacy Policy

Platform Data We Collect

When our Districts create an account for their users, certain information about teachers, students, and other users is electronically synced from the District’s information systems to the Platform. This information may include:

Log-in information;

First and last name;

E-mail address;

School and District name;

Student grade level;

Student language proficiency;

Student IEP status;

Student date of birth; and

Student ethnicity.

Depending on the features offered by the Platform, users may have the ability to provide additional information and content, including posts, communications, profile information, assessment scores, and survey responses, as well as to upload documents and files. We do not collect geolocation, biometric, or health data.

We and our service providers use cookies and other tracking technologies to automatically receive and record information on our server logs from a user’s browser or device, which may include:

IP address;

Cookie information;

Type of browser and/or device used to access the Platform; and

Pages or features the user requests.

Users may be able to change the preferences on their browser or device to prevent or limit their device's acceptance of cookies, but this may prevent them from taking advantage of some Platform features.

Morgan Bennett

Joseph Locke

Lawrence Frields

Debra Brock

Kevin Tiller

Pam White

Logan Mauldin

Daniel Duncan

David Harvey

Paige Bowers

Technology Documents

Chromebook 1:1 Documents

Technology Purchasing Requests

Rule 6A-1.0955, Florida Administrative Code - Online Educational Service Personally Identifiable Information Disclosures

Registration through Clever:

Other user information we collect:

“Do Not Track” Signals.

Cookies-

Analytics-

Advertising-

a. Information we collect directly from you or from your school

g. How We Use De-Identified Student Data