(Effective & Last Modified January 18, 2018)
- We may share your personally identifiable information, Non-PII and any other information we obtain from you via the Website with the applicable Member School.
- INFORMATION WE COLLECT
Our Website typically collects two kinds of information about you: (a) information that you provide that personally identifies you; and (b) information that does not personally identify you, which we automatically collect when you visit our Website or that you provide us.
(1) Personally Identifiable Information: Our definition of personally identifiable information includes any information that may be used to specifically identify or contact you, such as your name, postal address, phone number, etc. As a general policy, we do not automatically collect your personally identifiable information when you visit our Website. In certain circumstances, we may request, allow or otherwise provide you an opportunity to submit your personally identifiable information in connection with a feature, program, promotion or some other aspect of our Website. For instance, you may provide your name, address, email address, and phone number when registering with our Website, sending us an email, participating in a survey using, or posting a general comment and/or recommendation on our Website. Certain information may not be personally identifiable when standing alone (e.g., your age), but may become so when combined with other information (e.g., your age and name). Whether or not you provide this information is your choice; however, in many instances this type of information is required to participate in the particular activity, realize a benefit we may offer, or gain access to certain content on our Website.
(2) Non-Personally Identifiable Information: Our definition of non-personally identifiable information is any information that does not personally identify you (“Non-PII”). Non-PII can include certain personally identifiable information that has been de-identified; that is, information that has been rendered anonymous. We obtain Non-PII about you from information that you provide us, either separately or together with your personally identifiable information. We also automatically collect certain Non-PII from you when you access our Website. This information can include, among other things, IP addresses, the type of browser you are using, the third party website from which your visit originated, the operating system you are using, the domain name of your Internet service provider, the search terms you use on our Website, the specific web pages you visit, and the duration of your visits.
(3) Responses to Requests for Information: If you are a Member School, we may from time to time request certain information about your students in the form of surveys or questionnaires. You may provide us such information by email, secure file transfer or other means of communication. Such information may include student directory information (as defined under the U.S. Family Educational Rights and Privacy Act), contact information for your personnel, and other information (“Survey Information”). Providing Survey Information is voluntary, and we ask that you please make sure that you only provide information you are permitted to provide under the U.S. Family Educational Rights and Privacy Act and other applicable laws.
- HOW WE USE & SHARE THE INFORMATION COLLECTED
(1) Personally Identifiable Information: The personally identifiable information you submit to us is generally used to carry out your requests, respond to your inquiries, better serve you, or in other ways naturally associated with the circumstances in which you provided the information (including internal research and development purposes). We may also use this information to later contact you for a variety of reasons, such as customer service, providing you promotional information for our products, or to communicate with you about content or other information you have posted or shared with us via our Website. You may opt-out from receiving future promotional information from us.
In certain instances we may also share your personally identifiable information with our third party vendors performing functions on our behalf (or on behalf of our affiliated companies) – e.g., vendors that process credit card orders, deliver our merchandise, administer our promotions, provide us marketing or promotional assistance, analyze our data, assist us with customer service, etc. Our vendors agree to use this information, and we share information with them, only to carry out our requests.
(2) Non-PII: We use Non-PII in a variety of ways, including to help analyze site traffic, understand customer needs and trends, carry out targeted promotional activities, and to improve our services. We may use your Non-PII by itself or aggregate it with information we have obtained from others. We may share your Non-PII with our affiliated companies and third parties to achieve these objectives and others, but remember that aggregate information is anonymous information that does not personally identify you.
(3) Responses to Requests for Information: We use Survey Information for internal research purposes to improve, enhance and further develop our products and services, as well as document our work and outcomes. We do not sell or disclose such information to third parties for commercial purposes.
- COOKIES AND PREFERENCE BASED ADVERTISING
We automatically receive and store certain types of non-personally identifiable information whenever you interact with us. For example, like many websites, we use “cookies” and “web beacons” (also called “clear gifs” or “pixel tags”) to obtain certain types of information when your web browser accesses our Website. “Cookies” are small files that we transfer to your computer’s hard drive or your web browser memory to enable our systems to recognize your browser and to provide convenience and other features to you. “Web beacons” are tiny graphics with a unique identifier, similar in function to cookies, and may be used to track the online movements of users, when an email has been opened, and to provide other information.
Examples of the information we collect and analyze in this manner include the Internet Protocol (IP) address used to connect your computer to the Internet; computer and connection information such as browser type and version, operating system, and platform; your activities our Website, including the products you view or searched for, as well as the URL you come from and go to next (whether this URL is on our Website or not); and cookie number. It is important to note that the cookies and Web beacons that we use do not contain and are not tied to personally identifiable information about you.
If you are concerned about cookies, you may be able to reject or delete a cookie manually from your hard drive through your internet browser or other programs. Please note, however, that some parts of our Website will not function properly or be available to you if you refuse to accept a cookie or choose to disable the acceptance of cookies.
- OTHER USES & INFORMATION
(1) IP Addresses: An IP address is a number that is automatically assigned to your computer whenever you are surfing the Internet. Web servers (computers that “serve up” web pages) automatically identify your computer by its IP address. When visitors request pages from our Website, our servers typically log their IP addresses. We collect IP addresses for purposes of system administration, to report non-personal aggregate information to others, and to track the use of our Website. IP addresses are considered Non-PII and may also be shared as provided above. It is not our practice to link IP addresses to anything personally identifiable; that is, the visitor’s session will be logged, but the visitor remains anonymous to us. However, we reserve the right to use IP addresses to identify a visitor when we feel it is necessary to enforce compliance with our Website rules or to: (a) fulfill a government request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our Website, or other users; or (d) in an emergency to protect the health and safety of our Website’s users or the general public.
(2) Email Communications: If you send us an email with questions or comments, we may use your personally identifiable information to respond to your questions or comments, and we may save your questions or comments for future reference. For security reasons, we do not recommend that you send non-public personal information, such as passwords, social security numbers, or bank account information, to us by email. However, aside from our reply to such an email, it is not our standard practice to send you email unless you request a particular service or sign up for a feature that involves email communications, it relates to purchases you have made with us (e.g., product updates, customer support, etc.), we are sending you information about our other products and services, or you consented to being contacted by email for a particular purpose. In certain instances, we may provide you with the option to set your preferences for receiving email communications from us; that is, agree to some communications but not others. You may “opt out” of receiving future commercial email communications from us by clicking the “unsubscribe” link included at the bottom of most emails we send, or as provided below; provided, however, we reserve the right to send you transactional emails such as customer service communications.
(3) Transfer of Assets: As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or all (or substantially all) of our assets, the personally identifiable information and Non-PII we have about you will be transferred to and used by this acquiring entity, though we will take reasonable steps to ensure that your preferences are followed. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.
(4) Other: Notwithstanding anything herein to the contrary, we reserve the right to disclose any personally identifiable or Non-PII about you if we are required to do so by law, with respect to copyright and other intellectual property infringement claims, or if we believe that such action is necessary to: (a) fulfill a government request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our Website, or other users; or (d) in an emergency to protect the health and safety of our Website’s users or the general public.
(5) Your California Privacy Rights: Residents of the State of California, under certain provisions of the California Civil Code, have the right to request from companies conducting business in California a list of all third parties to which the company has disclosed certain personally identifiable information as defined under California law during the preceding year for third party direct marketing purposes. You are limited to one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for our response. You may request the information in writing as provided in Section I.
- PUBLIC FORUMS
The features, programs, promotions and other aspects of our Website requiring the submission of personally identifiable information are not intended for children, unless you are a student of Member School and have been granted a Membership. We do not knowingly collect personally identifiable information from children under the age of 13 who do not have a Membership. If you are a parent or guardian of a child under the age of 13 and believe he or she has disclosed personally identifiable information that you wish to have deleted or modified, please contact us at as provided in Section I.
- KEEPING YOUR INFORMATION SECURE
We have implemented security measures we consider reasonable and appropriate to protect against the loss, misuse and alteration of the information under our control. Please be advised, however, that while we strive to protect your personally identifiable information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and are not responsible for the theft, destruction, or inadvertent disclosure of your personally identifiable information. In the unfortunate event that your “personally identifiable information” (as the term or similar terms are defined by any applicable law requiring notice upon a security breach) is compromised, we may notify you by e-mail (at our sole and absolute discretion) to the last e-mail address you have provided us in the most expedient time reasonable under the circumstances; provided, however, delays in notification may occur while we take necessary measures to determine the scope of the breach and restore reasonable integrity to the system as well as for the legitimate needs of law enforcement if notification would impede a criminal investigation. From time to time we evaluate new technology for protecting information, and when appropriate, we upgrade our information security systems.
- OTHER SITES/LINKS
Our Website may link to or contain links to other third party websites that we do not control or maintain, such as in connection with purchasing products referenced on our Website and banner advertisements. We are not responsible for the privacy practices employed by any third party website. We encourage you to note when you leave our Website and to read the privacy statements of all third party websites before submitting any personally identifiable information.
- CONTACT & OPT-OUT INFORMATION
We will respond to your request and, if applicable and appropriate, make the requested change in our active databases as soon as reasonably practicable. Please note that we may not be able to fulfill certain requests while allowing you access to certain benefits and features of our Website.
- SOLE STATEMENT