Last Updated: January 9, 2017
Who are the Users of the Sites? Certain of our Sites host our GoReadWrite solution, which has been developed for use by students from grade 5 to college, for the improvement of writing skills and achievement. Students are provided access to our Software and Sites through their schools and school districts (collectively, “Local Educational Agencies” or “LEAs”), who utilize these services to assess their Students’ progress and supplement their mathematics curriculum. Homeschooled Students may also access versions of our Software that are licensed by their parent or legal guardian for homeschool use, per the terms of our end user license agreement for such Software (“Homeschooling EULA”). “Users” of our Sites include these Students; authorized representatives of the LEAs, including the Students’ teachers; parents / legal guardians of the Students; and other visitors to our websites and mobile applications.
What Student information does Gates Education collect itself from the Sites and Software? We may collect or generate certain information automatically from the Student’s use of the Sites, including login and logout timestamps. We may also collect and generate additional information about students through their use of the Software (“Student Performance Data”), including measurements / assessments of Student’s progress against the GoReadWrite curriculum as well as applicable educational standards; GoReadWrite quiz scores; and information derived and reports generated from the foregoing information and the Students’ use of the Software, for utilization by the Students, their parents / legal guardians, teachers, and the LEAs.
How does Gates Education use Student Records? We may use Student Records for the following purposes:
· To monitor and generate Student Performance Data, and provide students, parents, and/or the students’ teachers or LEAs, with Student Performance Data;
· To operate our software and Sites, including personalizing / customizing content for the applicable Students, reviewing / analyzing Site performance; authenticating Students; maintaining the Sites; and protecting the security or integrity of the Sites.
We may also use aggregated or de-identified information about Students, from which we have removed personally identifying information, for educational research, analysis, and similar purposes.
For the avoidance of doubt, we will not utilize any personally identifiable information in Student Records for the purposes of targeted advertising.
What Other Personal Information does Gates Education collect from its Users?Additional information gathered by Gates Education via the Sites falls into the following categories: (1) information voluntarily supplied by non-Student Users through optional online forms completed by such Users of our websites when requesting additional information about Gates Education or its products or services, or through Communications (as defined below) with Gates Education; (2) information automatically obtained from the use of User names and password to access the restricted portion(s) of the Sites (the "Restricted Pages") to do things such as view online demonstrations or presentations about Gates Education or its products or services, including, by way of example, pages visited and time stamps; and (3) tracking information gathered as Users navigate through our websites or mobile applications.
In visiting or using our Site and in transmitting Communications with us, you may be asked for, and we may collect, the following types of personally identifiable information from non-Student Users including: legal name; business name (if applicable); e-mail address; or user name and password). Gates Education may also ask for additional personal information from non-Student Users at various times such as when we run a promotion or contest or conduct a survey, as described in such promotion or contest, or elsewhere on the Site. The personally identifying information we collect from non-Student Users helps us offer Users more personalized features, respond to User requests, provide you with information that is of most interest to you, improve our products and services, and, to the extent that you consent to such communications, send you promotions and events offered by Gates Education.
Does Gates Education track my IP address? When you visit the Site, our web servers automatically collect information about your Internet address (which is a number that lets computers attached to the Internet know where to send you data). Your Internet address does not identify you personally. We log your Internet address to deliver our web pages to you upon request, help diagnose problems with our server, administer our Site in order to constantly improve its quality and the services we offer you, and identify and authenticate you and your licensed content and preferences as you navigate the Site. We may also use your Internet address to gather broad demographic information. We may also track and analyze non-identifying and aggregate usage and volume statistical information from our visitors and users and provide such information to third parties.
How does Gates Education use information collected from me? Gates Education researches our customers' and visitors' demographics based upon information provided by them or, their LEAs (if applicable), gathered from their Communications or password, or contained in our server log files or surveys. We do this to better understand and serve our customers and visitors. This research is compiled and analyzed on an aggregated basis.
How does Gates Education share information? Gates Education does not provide, sell, trade, or rent personally identifiable information. We may disclose or share personally identifying information as follows:
To our service providers. We may share personally identifying information collected through the Site or otherwise in our possession with companies and organizations that perform services on our behalf, for example, companies that provide data management or other support services to us (such as data storage and Web hosting services), subject to confidentiality and security obligations.
To parents / legal guardians. We may provide Student Records or Student Performance Data to the Students’ parents / legal guardians.
To teachers / LEAs. We may provide Student Records and corresponding Student Performance Data to the teachers or other authorized LEA representatives for the applicable student Users.
In a business transfer. We may transfer personal information and other data in our possession in connection with an acquisition by or merger with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding.
How do I review, correct, update and / or remove my personal information or my child’s personal information?
Reviewing and updating Student Records. Parents, legal guardians, and Students aged 13 and above may review the personally identifying information contained in Student Records and may have us correct any erroneous Student Records. We will terminate use and storage of any personal information contained in Student Records received from the LEA following written notice of termination, unless we have received consent directly from such Student, if aged 13 or above, or the Student’s parent or legal guardian otherwise, to store such Student Records. We will terminate use and storage of any personal information contained in Student Records that we have collected for children under 13 following written request from their parent or legal guardian. To exercise these rights, you may contact us at firstname.lastname@example.org. To review Student Records for Students under the age of 13, you will be required to authenticate yourself as the Student's parent / legal guardian, teacher, or other authorized LEA representative to receive information about that Student. You agree and acknowledge that the Sites or Software, or features of the Sites or Software, may be inaccessible or inoperable upon removal of Student Records.
Review and updating other User information. Non-Student Users may review update and/or correct your contact or other personal information at any time by sending an e-mail to us at email@example.com and/or notifying Gates Education of the changes, as applicable. If you have been prompted to provide information to register an account, you will be provided limited access to your account information to update and/or correct the personal information you have supplied.
How does Gates Education protect personal information? Our Site has security measures in place to minimize the risk of loss, misuse, and alteration of the information under our control. Your access to the Restricted Pages or other accounts (if you have any) established through Gates Education or the Site is password-protected so that only you have access to that personal information, so keep your password private and secure.
We provide and require training of all of our personnel involved in the handling, usage, or storage of Student Records or other personally identifying information, which training is renewed periodically. This training includes compliance with relevant federal and state legal requirements, including, as a non-limiting example, the federal Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g) (“FERPA”) and the Children’s Online Privacy Protection Act (15 U.S.C. Secs. 6501 – 6506) (“COPPA”). To protect our information technology environment and the data that we store, we take commercially reasonable security measures, implemented with a multi-tier software architecture, that are consistent with standards generally recognized in the industry. Please be aware, however, that despite our efforts, no security measures are perfect or impenetrable. Due to the open nature of the Internet, we cannot guarantee that any of your information stored on our servers, or transmitted to or from a us or a user, will be 100% free from unauthorized access, and we disclaim any liability for any theft or loss of, unauthorized access or damage to, or interception of any data or communications. By using the Site, you acknowledge that you understand and agree to assume these risks.
How does Gates Education respond to breaches? If you correspond with us by e-mail, or using the “contact us” feature on the Site, you should be aware that your transmission might not be secure. We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission. If we believe that the security of User information may have been compromised, we will comply with applicable laws and regulations regarding notice of such breaches. Without limiting the foregoing, we will notify any LEA whose data is affected by such a breach, and will provide any reasonable cooperation to the LEA to notify affected parents / legal guardians in the event of an unauthorized disclosure of student records. You consent to our use of your e-mail address as a means of such notification. Please notify us of any unauthorized use of your password or account or any other breach of security of which you are aware.
Will Gates Education send me unsolicited communications? How do I opt-out? Gates Education may use the information it collects to respond to requests for information, to notify you about functionality changes to the web site, or to provide industry and company updates. You may update or modify your information or change your privacy preferences (such as whether you wish to receive promotional offers) at any time by emailing us at firstname.lastname@example.org. If you wish to have your name removed from any of our mailing or subscription lists, please write to us at our above address or click the “remove subscription” link set forth in the relevant communication (typically provided at the end of such communication). In the event that you contact us with this request, all reasonable efforts will be taken to ensure that you will not receive any further communications from which you have opted-out in the future.
How does Gates Education respond to Do-Not-Track signals? In some cases, third parties may be able to collect information about a user’s online activities over time and across different websites when he or she uses our Site or services. Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. Because there currently is no industry standard concerning what, if anything, websites should do when they receive such signals, we currently do not take action in response to these signals.
How do I contact Gates Education? What are my information rights? If you have any questions about this privacy statement, the practices of this Site, your dealings with this Site, or any disclosure of personal information to third parties for direct marketing purposes, you can contact us in the following ways:
Mail: Gates Education
Irvine, CA 92620