IMPORTANT NOTICE FOR SCHOOL USERS
PROTECTION OF STUDENT DATA
WHAT WE COLLECT
Information a Teacher or Parent Gives Us
We collect personal information you provide to us, which may include personal information of your students if you provide us with such information. By providing us with personal information about your students, you are representing to us that you have all necessary authority or consent to provide us with such information. For example, in connection with your use of the Services, you may provide us your name, country, postal code, email address, username, password, and other information, including demographic information and information about your classroom, your school, and your students. We also collect writing by teachers, including but not limited to annotations, feedback and assignment prompts that teachers provide to students using the Services. If you order our premium services or products, we will collect all information necessary to complete the transaction, including your name, credit card information, billing information, and shipping information (as applicable). This transaction-related information may be shared with third parties who help process and fulfill your transaction. We require these third parties to use your transaction-related information only for the purposes of processing and fulfilling your transactions and for no other purposes. For more information about how your personal information is shared, please see the section of this Policy titled “Sharing of Personal Information” below.
Information a Student Gives Us
We collect any personal information a student directly provides to us through use of the Services, including a student’s name, classroom affiliation, username, and password. We also collect information about how a student interacts with the Services, including the articles that a student reads, the types of articles a student has expressed interest in, quizrelated information, responses a student writes to teacher assignment prompts, how much time a student spends reading the articles, and other performance related information. We also collect writing by students in many forms, including but not limited to their annotations and written responses to writing prompts. We may also collect information about a student provided by a school.
Information about You and Your Student that Your School Gives Us
We collect personal information about you and/or your student that your school, school district and/or their administrators choose to provide to and share with us, directly and through third party service providers.
Information Automatically Collected from You and Your Student
We may use unique identifiers to track individual usage behavior on our Services, such as length of time spent on a particular page and pages viewed during a particular log-in period. The unique identifiers collect information about a user’s use of the Services on an individual basis. We use the information that we gather through unique identifiers to evaluate and improve the Services and its content, including, but not limited to, improving and evaluating the effectiveness of certain materials on our Services and the student and teacher experience while using the Services.
Web beacons, or clear GIFs or pixel tags, are small graphic image files that can be embedded in web pages or emails to collect information about a user’s use of our Services or the correspondences that we send to them. The information collected by web beacons allows us to analyze how and how many people are using the Services or when users open our emails. Web beacons also allow us to enhance our Behavioral Advertising, which is further discussed below in the section titled [“Interest-based and Behavioral Advertising”] (#”INTEREST-BASED OR ONLINE BEHAVIORAL ADVERTISING”).
ANALYTICS AND OTHER TECHNOLOGIES
MOBILE DEVICE IDENTIFIERS
Mobile device identifiers are identifiers stored on your mobile device that may track your mobile device and data and activities occurring on or through it, as well as the applications installed on it. Mobile device identifiers enable collection of personal information (such as media access controls) as well as non-personally identifiable information (such as usage and traffic data). As with other Tracking Tools, mobile device identifiers help InterEd learn more about our users’ demographics and internet behaviors and operate and improve the Services.
THIRD PARTY ACCOUNT CONNECTIONS
If you or your student chooses to log on or otherwise associate the Services with another third party account (for example, a Google Account), we may receive information from that third party site to make it easier for you or your student to create an account on the Services and display relevant content. Any information that we collect from these third party accounts may depend on the privacy settings you or your student has with that third party, so please consult their privacy and data practices.
USE OF PERSONAL INFORMATION
We use information collected through our Services, or disclosed by you on our Site or App or in connection with our Services, for the purposes described in this Policy. For example, we may use your and your student’s information to:
・understand your student’s performance in relation to others, and to provide you and your student with insight into their performance;
・understand your and your student’s preferences and to enhance your and your student’s experience and enjoyment using our Site, App, and Services;
・operate, maintain, and improve our Site, App, and Services;
・respond to comments and questions and provide customer service;
・send you related information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
・create advertisements shown to teachers and administrators that reflect the interests and capabilities of their students and communicate with teachers and administrators about promotions and other news about Services offered by us (Note: InterEd never directs targeted advertising at Children. See: “Interest-Based or Online Behavioral Advertising,” below.);
・customize advertisements and communicate about promotions and other news about Services offered by us;
・protect, investigate, and deter against fraudulent, unauthorized, or illegal activity;
・link or combine with other personal information we get from third parties such as your associated school, to help understand your needs and provide you with better service; and
・provide and deliver products and services that you request.
We will not use your personal information in any way other than in connection with providing the Services, as described in this Policy, as directed by a teacher or school, or upon obtaining your consent.
SHARING OF PERSONAL INFORMATION
We do not share your or your student’s personal information except as follows:
・with your school or school district at their request;
・with third party service providers, consultants, and other service providers who perform services for us and need access to your or your student’s information to do that work in a manner consistent with this Policy (for example, our web hosting provider, third party analytics service providers, advertising services providers, and purchase processors. Note: InterEd never directs targeted advertising at Children. See: “Interest-Based or Online Behavioral Advertising,” below.);
to comply with laws or to respond to lawful requests and legal process;
・in an emergency to protect the personal safety of our users or any person;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.
Additionally, we may share your or your student’s personal information with new teachers who use the Services in their classrooms when you or your student, as applicable, enroll in such teachers’ classes, and we may share teacher personal information with other teachers within a school using the Services. We may create and use anonymized and/or aggregated data for our own purposes by excluding information (such as your or your student’s name) that makes the data personally identifiable to you or your student. The purposes for which we may create and use anonymized and/or aggregated data include but are not limited to, conducting analysis and generating statistics regarding the use of our Site, App, and/or Services. We will not share your or your student’s personal information in any way other than in connection with providing the Services, as described in this Policy, as directed by a teacher, parent/legal guardian or school, or upon obtaining your consent. We require our third party service providers not to use your or your student’s personal information other than to provide the services that we have requested. We will not disclose your or your student’s personal information to any third party for that third party’s own marketing purposes. Additionally, we will not knowingly use or disclose student information (whether personal information or otherwise) for behavioral targeting of advertisements to such students. We do not sell student 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 a text set to a student based on the student having read a similar text set in the past, or based on the student’s age or grade level.
INTEREST-BASED OR ONLINE BEHAVIORAL ADVERTISING
We may advertise to teachers and administrators using a type of advertising known as interest-based or online behavioral advertising (“Behavioral Advertising”). Behavioral Advertising is the use of Tracking Tools by us or our Advertising Service Providers (defined below) to display InterEd ads on other websites or services based on information about a user’s use of the Services or on the user’s interests (as inferred from the user’s online activity).
For clarity, InterEd’s Behavioral Advertising is intended for teachers and administrators; we do not behaviorally target advertising to student users on sites that are directed to student users.
InterEd adheres to the Digital Advertising Alliance Self-Regulatory Principles for Online Behavioral Advertising (“OBA Principles”). More information about the OBA Principles can be found at http://digitaladvertisingalliance.org/blog-terms/daa-principles.
Advertising Service Providers
We may work with third parties that use Tracking Tools to collect and use information about your access and use of the Services and non-affiliated websites and applications in order to provide Behavioral Advertising and related services to you and us (“Advertising Service Providers”), for example by facilitating targeting of advertisements and measuring and analyzing advertising effectiveness and traffic on the Services, (collectively, all such services, “Targeting Services”). Advertising Service Providers include advertising networks, data exchanges, traffic measurement service providers, marketing analytics service providers, and other third-party service providers. Targeting Services enable us to display advertisements based on your use of the Services and other websites or applications you have visited, including for InterEd content, products or services that may interest you. Targeting Services can also help prevent you from seeing repeated advertisements and enable us to research the usefulness of certain advertisements. Our Advertising Service Providers do not have access to Tracking Tools set by us or on our Services except to the extent necessary to provide services to InterEd.
Opting Out of Behavioral Advertising
You can opt-out of certain Behavioral Advertising activities by doing one or more of the following. Please note that you will need to opt-out of each browser and device for which you desire to apply these opt-out features.
・Service Provider Opt Out:
You can opt-out of the use of information for Behavioral Advertising by certain Advertising Service Providers we use by using their opt-out tools. Some of these Advertising Service Providers, and links to their opt-out tools, are:
・Industry Opt Out Tools:
Some Advertising Service Providers may participate in the Network Advertising Initiative’s (NAI) Opt-Out Tool (http://www.networkadvertising.org/choices/) and/or the Digital Advertising Alliance (DAA) Consumer Choice Page (http://www.aboutads.info/choices/), and therefore you can opt-out of certain services by those Advertising Service Providers (and other NAI or DAA member companies) by visiting the links included here. Please click on the links to these tools to learn more about your choices.
・Web Browser Controls:
You can prevent the use of certain Tracking Tools on a device-by-device basis by using the controls in your web browser. These controls can be found in the Tools > Internet Options menu for your browser, or as otherwise directed by your browser’s support feature. Through your web browser, you may be able to:
○Delete existing Tracking Tools
○Disable future Tracking Tools
○Set your browser to provide you with a warning each time a cookie or certain other Tracking Tools are being set
・Mobile Opt Out:
Your mobile devices may offer settings that enable you to make choices about the collection, use, or transfer of mobile app information for Behavioral Advertising. You may also opt-out of certain Tracking Tools on mobile devices by installing the DAA’s AppChoice app on your mobile device
(for iTunes, visit https://itunes.apple.com/us/app/appchoices/id894822870?mt=8,
for Android, visit https://play.google.com/store/apps/details?id=com.DAA.appchoices&hl=en).
For more information, please visit http://support.apple.com/kb/HT4228, or https://support.google.com/ads/answer/2662922?hl=en and http://www.applicationprivacy.org/expressing-your-behavioral-advertising-choices-on-amobile-device, as applicable.
Please note the following with respect to opting out of Behavioral Advertising:
・Some opt-out features are cookie-based, meaning that when you use these opt-out features, an “opt-out” cookie will be placed on your computer, tablet or mobile device indicating that you do not want to receive Behavioral Advertising from certain companies. If you delete your cookies, use a different browser, use a different device or buy a new computer or mobile device, you will need to renew your opt-out choice
・Opting-out of, deleting, rejecting, disabling or turning off Tracking Tools does not mean that you will no longer receive online ads. Opting-out of Behavioral Advertising only means that such ads will no longer be tailored to your specific viewing habits or interests, but you may continue to see ads on and about the Services.
How We Respond to Do Not Track Signals
We do not currently respond to “do not track” signals or other mechanisms that might enable consumers to opt-out of tracking on our Services.
INFORMATION CHOICES AND CHANGES
Below are some ways you can control the collection and use of your and/or your student’s information in connection with the Services. While we and others give you choices described in this Policy, there are many ways web browser signals and other similar mechanisms can indicate your choice to disable tracking, and we may not be aware of or honor every mechanism.
You may “opt-out” of receiving our promotional emails by following the instructions in those emails. If you opt-out, we may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our transactions with you.
Information in the Services
You may change some of your or your student’s personal information stored in the Services by following the directions on the Site or App. You may send requests about your or your student’s personal information, including requests to change your or your student’s contact preferences and update or correct your or your student’s personal information, to our contact information below. In some cases, changes about a student’s personal information may have to be executed by the student’s school or teacher, and in such situations, we will attempt to assist you and the school or teacher with such efforts.
Behavioral Advertising and Tracking Tools
You can opt-out of certain mechanisms for tracking, including tracking of your online activities over time and across different websites, by using one or more of the options described above in the “Interest-Based and Behavioral Advertising” section of this Policy.
You may prohibit us from disclosing your or your student’s personal information with a third party by contacting us at the information provided below to opt-out of such disclosures in advance; provided that if you prohibit us from sharing your or your student’s personal information with your or your student’s school or our third party service providers, we may not be able to provide the Services to you or your student. Additionally, you cannot prohibit us from sharing your or your student’s personal information when reasonably necessary to defend the rights or property of us, including our Services, or anyone else or as reasonably necessary to comply with relevant laws or respond to a legal request.
You may review your or your student’s personal information by logging into your or your student’s account or by sending us an email or postal mail at the address below.
We will retain your or your student’s personal information, including after the school term in which you or your student uses the Services, for only as long as is reasonably necessary to fulfill the purpose for which the information was collected. Generally, InterEd will delete a user’s personal information 4 years after the user’s last login to the Services.
You may request deletion of your or your student’s personal information by sending us an email or postal mail at the address below. IN SUCH CASE, WE WILL NO LONGER ALLOW THE APPLICABLE USER TO USE THE SERVICES. We will delete your or your student’s information using reasonable measures to protect against unauthorized access to, or use of, the information in connection with its deletion. When we delete a user’s personal information, it will be deleted from our active databases but we may retain an archived copy of such user’s records as required by law or for legitimate business purposes.
Refusing Further Collection or Use
You may at any time refuse to permit our further use or future online collection of your or your student’s personal information, by terminating your or your student’s account and directing us to delete your or your student’s personal information (as described above). IN EITHER CASE, WE WILL NO LONGER ALLOW THE APPLICABLE USER TO USE THE SERVICES. We will not have any liability whatsoever for any termination of the account or related deletion of your or your student’s personal information. After termination, a terminated user will not be able to use his or her account anymore. Access to schoolwork associated with the account will no longer be available to such user.
Reliance on Teacher or Parental Instructions
We may, and you authorize us to, rely on the instructions that we reasonably believe are given by a teacher, parent or legal guardian in connection with a student. For example, if a person calls our customer support number and provides the account information we request, we may assume that the person calling is the teacher, parent or legal guardian of such student. We will not be held liable for any disclosure made in good faith and following reasonable procedures in responding to a request for disclosure of a student’s information from such individual.
Different rules might apply to the collection, use or disclosure of your information by third parties in connection with their advertisements, promotions and other websites you encounter on the Internet. The use of such technology by these third parties, and their policies and practices regarding your information and their sites and services, is within their control and not InterEd’s. Those parties may use the information they collect from you consistent with their own privacy policies, which we encourage you to carefully review.
SECURITY OF YOUR PERSONAL INFORMATION
We encrypt the transmission of your and your student’s personal information using security measures designed to protect the security, privacy, confidentiality, and integrity of personal information against risks through the use of administrative, technological, and physical safeguards. We also take reasonable steps to release Children’s personal information only to third parties who are capable of maintaining the confidentiality, security and integrity of such information, and who provide assurances that they will maintain the information in such a manner. Despite our efforts, however, third parties may still find ways to hack into the Services and intercept data transmissions. Therefore, although we take security very seriously and work very hard on behalf of your and your student’s privacy, we cannot guarantee the security of your or your student’s information.
We welcome your comments or questions about this Policy. Feel free to email us at email@example.com.
We may change this Policy from time to time. If we make any changes to this Policy, we will change the Last Revised date above. If we make material changes to this Policy, we will send a notice to the email address we have on file for the account holder. For material changes regarding use or collection of data, we will provide choices and additional information regarding the collection of such data before it is used in any manner inconsistent with the terms initially provided to users.