Last Updated: May 12, 2020
INFORMATION YOU PROVIDE TO US
Account Information. We receive and store any information you knowingly provide to us. You must create an account in order to use the Services (the “Account”). Through the registration process and/or through your Account settings, we may collect personal information such as your name, email address, school, school address, title, and other information about your interests and preferences (collectively “Personal Information”). Any other information combined with your Personal Information will be treated together as Personal Information.
Information Collected Through Your School. We will add information to your Account provided by your school that the school may provide to us in connection with our Services. ABC understands that it is important that our partner schools comply with the Family Education Rights and Privacy Act (“FERPA”) and related regulations. Certain information collected through your school that may be provided to ABC that is directly related to a student and maintained by your school, may be considered an education record (“education record”) under FERPA.
INFORMATION COLLECTED AUTOMATICALLY
Like many website owners and operators, we use automated data collection tools such as Cookies and Web Beacons to collect certain information. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the ABC Site.
The technologies and information we automatically collect include:
“Web Beacons” (also known as Web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included in the Services and Site for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of the Services, to monitor how many visitors view the Services.
Information Related to Use of the Services. Our servers may automatically record certain information about how a person uses the Services or Site (“Log Data”). Log Data may include information such as a user’s Internet Protocol (IP) address, browser type, operating system, the web page that a user was visiting before accessing our Site or the Services, the pages or features of the Services to which a user browsed and the time spent on those pages or features, search terms, the links on the ABC Site or Services that a user clicked on and other statistics. We use Log Data to administer the Services and we analyze (and may engage third parties to analyze) Log Data to improve, customize and enhance the Services by expanding their features and functionality and tailoring them to our user’s needs and preferences. We may use a person’s IP address to generate aggregate, non-identifying information about how the Services is used.
Information Sent by Your Device. We collect certain information that the device from which you are using the Services and Site (such as, mobile phone, iPad, computer, etc.) sends when you use the Services and Site, like a device identifier, user settings and the operating system of your device, as well as information about your use of the Services and Site.
Location Information. When you use our Site, we may collect and store information about your location by converting your IP address into a rough geo-location or by accessing your mobile device’s GPS coordinates or coarse location if you enable location services on your device. We may use location information to improve and personalize the Services for you.
HOW WE USE YOUR INFORMATION
We use information about you in the following ways:
- Information You Give To Us. We will use this information:
- to provide you with the information and services that you request from us;
- to provide you with information about goods or services we feel may interest you. We will only contact you by electronic means (e-mail or SMS) where you have consented to this, or where we can otherwise lawfully do so.
- to notify you about changes to the Services;
- to ensure that content from ABC is presented in the most effective manner for you and for your computer.
- Information Automatically Collected. We will use this information:
- to administer ABC and for internal operations, including troubleshooting, site traffic, data analysis, testing, research, statistical and survey purposes;
- to improve ABC to ensure that content is presented in the most effective manner;
- as part of our efforts to keep ABC safe and secure;
- to make suggestions and recommendations to you and other users of ABC about goods or services that may interest you or them.
Our primary goals in collecting information are to provide and improve our Services, to administer your use of the Services (including your Account, if you are an Account holder), and to enable you to enjoy and easily navigate the Services. We will use your Personal Information to:
- Administer the Services, communicate with you and provide customer support in relation to the Services.
- Resolve disputes, collect fees (if any) and troubleshoot problems.
- Customize your experience and otherwise measure and improve the Services.
- Send you relevant emails and communications (including keeping you informed about our products, offerings and any promotional offers) that might be of interest to you (If we use your personal information to market to you, you will be able to opt-out of such uses).
- Enforce our agreements, terms, conditions, and policies, and send you notices and alerts.
Additionally, we may offer you products and services that may be of your interest. You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications.
INFORMATION THAT WE SHARE WITH THIRD PARTIES
Information Shared with Authorized Viewers. We may share your information, including your Personal Information, with individuals that you have explicitly authorized us to share your information (“Authorized Viewers”).
Information Shared with Our Service Providers. We may engage third-party services providers to work with us to administer and provide the Services (e.g. companies that provide us services such as hosting and maintenance of our Site, data storage and management, etc.). These third-party services providers have access to your Personal Information only to the extent needed to perform services on our behalf.
Information Shared with Third Parties. From time to time in the course of our business or operations, we may collaborate with other educational partners to collect, analyze and process data relating to our student users. Such collaboration enables us to grow and improve our Services. Generally, any such data is collected in an aggregated and anonymized format, which means that Personal Information will not be included in any such collected data. Your use of the Site and Services constitutes your consent to the collection and sharing of aggregated, anonymized data with such third parties in the manner described in this paragraph. In the event that any data is shared with third parties in a manner that contains Personal Information, we will take reasonable efforts to ensure that our users have consented to the collection and sharing of such Personal Information.
Analytics Services. We use analytics services, including mobile analytics software, to help us understand and improve how the Services are being used. These services may collect, store and use information in order to help us understand things like how often you use the Services, 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 information (information about our users that we combine together so that it no longer identifies or references an individual user) and other non-personally identifiable information, including with users, partners or the press in order to, for example, demonstrate how the Services is used, spot industry trends, or to provide marketing materials for ABC. Any aggregated information and non-personalized information shared this way will not contain any Personal Information.
FAMILY EDUCATIONAL RIGHTS AND PRIVACY ACT (“FERPA”)
ABC may use education records that have been de-identified for product development, research or other purposes permitted by applicable law (“de-Identified data”), including:
- To demonstrate the effectiveness of the Services, including in our marketing materials; and
- To develop and improve our educational products.
ABC will not attempt to re-identify the de-Identified data nor will we transfer the de-Identified data to a third-party unless that party agrees not to attempt re-identification.
We offer you choices regarding the collection, use and sharing of your Personal Information and we’ll respect the choices you make. Please note that if you decide not to provide us with the Personal Information that we request, you may not be able to access all of the features of the Services.
Modifying and Deleting Your Information. You can access, export and modify the Personal Information associated with your Account by sending us an email at firstname.lastname@example.org.
If you want us to delete your Personal Information and your Account, please email us at email@example.com with your request. ABC retains the data we collect for different periods of time depending on what it is and how we use it. We keep some data until you delete your Account, such as information about how often you use our services.
ABC retains some data for longer periods of time when necessary for legitimate business or legal purposes, such as security, fraud and abuse prevention, or financial record-keeping.
When ABC deletes data, ABC follows a deletion process to make sure that your data is safely and completely removed from our servers or retained only in anonymized form. As a result, there may be delays between when you delete something and when copies are deleted from our active and backup systems.
HOW WE PROTECT YOUR INFORMATION
ABC uses commercially reasonable information security safeguards to protect its databases and servers against risks of loss, unauthorized access, destruction, misuse, modification, or inadvertent or improper disclosure of data. ABC segregates certain personally identifiable and other information about your use of ABC’s Services into separate databases, some of which can be accessed only by a limited number of employees. Your ABC Account is protected by a password. You can help us protect against unauthorized access to your Account by keeping your password secret at all times.
We restrict access to personal information to authorized ABC administrators, agents or independent contractors who need to know that information in order to process it for us, and who are subject to strict confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
LINKS TO OTHER SITES
OUR POLICY TOWARD CHILDREN
The ABC Site and Services are not intended for use by children under the age of 13 and does not knowingly collect personal information from children under 13 years of age. If you believe that your child or student may have provided us with personal information without parental consent, you may contact us at firstname.lastname@example.org. If we learn that we have collected Personal Information of a child under 13 we will take steps to delete such information from our files as soon as possible.
RESPONDING TO DO NOT TRACK SIGNALS
Our Site and Services does not have the capability to respond to “Do Not Track” signals received from various web browsers.