Privacy Policy
Revision date: October 3, 2022
This Privacy Policy describes the personal information SASC, LLC (“Activate Learning”, “we”, “our”, or “us”) collects, how we use this information, with whom we share it, and the choices you have in connection with this. This Privacy Policy applies to Activate Learning’s interactive educational platform (the “Platform”), websites located at activatelearning.com, Iqwst.com, activatelearningdigital.com, and ebook.activatelearning.com (collectively, the “Websites”), and e-Book application (“e-Book”) (collectively, the “Services”).
The Platform and e-Book are provided through educational institutions that contract with us to provide the Platform and/or e-Book to their respective students and teachers. The Websites are available to any person but are directed to educational institutions for informational purposes.
Information We Collect and How We Use It
1. Information We Collect in Connection with Providing Educational Institutions with the Platform
- We collect personal information directly from you to:
- Add Teachers to a license: To add teachers or administrators to a license for the Platform, we collect their identifiers (name, email address) from the educational institution. We use this personal information to create an account for the Platform.
- Complete Registration (non-LMS): When a teacher or student is registered, we collect from the educational institution the following identifiers (name, email address, SIS ID and course enrollment). We use this information for the purpose of Platform account management.
- Login to the Platform (non-LMS ): When teachers and students log in to the Platform, they provide their identifiers (username and password). We use this information to authenticate the user and provide access to the Platform.
- Participate in the Platform: As students participate in their educational institution’s license for the Platform, we collect students’ identifiers (name, email, username, student identification number), and education information (enrolled school and classes for science instruction, student grade level, grades, assignments, notes). We use this personal information to facilitate the functionality of the Platform and integration with the students’ applicable class.
- Make a purchase: When an educational institution purchases a license, we collect, from the educational institution, payment information (credit card number, expiration date, and CVV) to process your payment. Please note our payment processor collects and processes this personal information directly on our behalf. We do not retain credit card information.
- We collect personal information from third parties to:
- Complete Registration (LMS): In LMS integrations, Activate Learning collects identifiers (name, email) and education information (course enrollment) from the teacher’s Learning Management System via syncs. When a teacher authenticates and selects classes, the teacher is added to the roster in the Platform along with all the students from the selected classes. This is the point at which a student account and teacher account are registered on the Platform. We use this information for the purpose of Platform account set up and administration.
- Complete Registration (Clever): When using Clever, Activate Learning receives data from the teacher’s Student Information System via nightly syncs. We collect identifiers (SIS ID, name, email) and education information (course enrollment) for both teachers and students. This is the point at which a student and teacher account are registered on the Platform. We use this information for the purpose of Platform account set up and administration.
- Login to the Platform (LMS): When a teacher or student logs in to the Platform, we collect user and student roster identifiers (teacher name, teacher email, and class names associated with our programs) through the Learning management System API. We use this information to update class roster information in the Platform.
2. Information we collect in Connection with Providing Educational Institutions with the e-Book
- Add Teachers to a license: To add teachers or administrators to a license for the e-Book, we collect their identifiers (name, email address) from the educational institution. We use this personal information to send an email invitation to create an account for the e-Book or a teacher account is activated manually via the e-Book administration panel.
- Complete Teacher Registration: When a teacher registers the educational institution’s class for the e-Book, it collects the teacher’s identifiers (name, email address, username, and password). We use this information for the purpose of e-Book account management.
- Login to the e-Book: When a teacher logs in to the e-Book application, we collect, from the teacher, the teacher’s identifiers (username and password). When a student logs in to the e-Book application, we collect from the student, the student’s identifiers (generic username and password). We use this information to authenticate the user and provide access to the e-Book application.
- Make a purchase: When an educational institution purchases a license, we collect, from the educational institution, payment information (credit card number, expiration date, and CVV) to process your payment. Please note our payment processor collects and processes this personal information directly on our behalf. We do not retain credit card information.
3. Information Collected in Connection with Your Use of Our Websites
- We collect personal information directly from you to:
- Fulfill a Product Request: When you request a certain product on our Websites, we collect from you your identifiers (name, email address, phone number, user role, city, and state), commercial information (product interest), and if applicable, professional information (school name, district name). We collect this information to fulfill your product request, as well as to send you direct email and telephone marketing communications. You can opt-out of any future marketing e-mail communications by clicking on the “unsubscribe” button on any Activate Learning marketing e-mail.
- Fulfill a Product Return: When you request to return a certain product, we collect from you your identifiers (name, email address, and telephone number), and commercial information (purchase history – product to be returned). We collect this information to process the user’s return request.
Activate Learning may also use your personal information collected for the above purposes to comply with the law and for other limited circumstances as described in INFORMATION SHARING.
- Cookies: In addition to the personal information you provide directly to us, we also collect information from you automatically as you use our Websites via cookies. This includes the following internet or other electronic network activity information:
- Usage information: We use strictly necessary and functional cookies to collect information about your interaction with our Websites, such as the pages you visit, the frequency of access, how much time you spend on each page, what you click on, and referring website address. We use this personal information to: (i) enhance user experience; (ii) prevent fraudulent use of the Services; and (iii) diagnose and repair errors.
- Device information: We use strictly necessary and functional cookies to collect certain information about the device you use to access our Websites, such as browser type, browser language, hardware model, operating system, and your preferences. We use this personal information to: (i) enhance user experience; (ii) prevent fraudulent use of the Websites; (iii) diagnose and repair errors; (iv) remember your preferences; and (v) provide enhanced functionality.
- Location information: We use strictly necessary and functional cookies to collect information about your location, which may be determined through your IP address. We use this personal information to: (i) enhance user experience; (ii) prevent fraudulent use of the Websites; (iii) diagnose and repair errors; (iv) remember your preferences; and (v) provide enhanced functionality.
Please visit our cookie management platform on activatelearning.com for a list of all cookies, their purpose, the information they collect, and for the ability to change your preferences. In general, to disable cookies and limit the collection and use of information through them, you can set your browser to refuse cookies or indicate when a cookie is being sent.
Particular third-party cookies on our Websites to note include:
- Google Analytics. We use Google Analytics to collect information on your use of the Website to improve our Website. In order to collect this information, Google Analytics may set cookies on your browser, or read cookies that are already there. Google Analytics may also receive information about you from applications you have downloaded that partner with Google. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to our Websites or to another application which partners with Google is restricted by the Google Analytics Terms of Use and the Google Privacy Policy available here. To prevent your data from being used by Google Analytics, you can download the Google Analytics opt-out browser add-on for Google Analytics which can be found here. We have implemented Restricted Processing which prevents the sharing of personal information that would constitute a “sale” under the CCPA. Please refer to the RIGHTS OF CALIFORNIA RESIDENTS section for more information.
Information Sharing
Activate Learning will share your personal information in the following instances:
- With Educational Institutions: Activate Learning will share student personal information with educational institutions to connect students with their teacher, facilitate instruction, and to identify the student to the teacher so that they are able to effectively issue instruction, review assignments, and grading.
- Within Activate Learning: Where necessary, Activate Learning will share your personal information within Activate Learning in order to provide product support and to the extent permitted by law.
- In the event of a corporate reorganization: In the event that Activate Learning enters into, or intends to enter into, a transaction that alters the structure of Activate Learning, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our assets, Activate Learning would share personal information with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction. Activate Learning would also share personal information with third parties if Activate Learning undergoes bankruptcy or liquidation, in the course of such proceedings.
- For legal purposes: Activate Learning shares personal information where legally required, such as in response to court orders, law enforcement or legal process, including for national security purposes; to establish, protect, or exercise our legal rights, as required to contracts; to defend against legal claims or demands; to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person; or to comply with the requirements of any applicable law.
- With service providers for a business purpose: In the past 12 months, Activate Learning has shared identifiers, payment information, internet and other electronic network activity information, and educational information with service providers that perform services on Activate Learning’s behalf. These service providers include our IT support, cloud application providers, customer relationship management platform, learning management system provider, payment processor, customer support, and email provider. We require that our vendors with whom Student PII is shared in order to deliver the educational service, if any, are obligated to follow our same commitments for the given Student PII. We contract with Sourcetoad for devops and programming services.
- With IT for a business purpose: In the past 12 months, Activate Learning has shared internet and other electronic network activity information with IT support to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, identify and repair Services errors, and to maintain and improve the Services.
Correct Or View Your Information
You can access your Activate Learning account to correct or view certain personal information of yours in our possession and which is associated with your account.
PARENT/GUARDIAN CHOICES
Activate Learning does not enable children to make their personal information publicly available. At any time, parents or guardians have the right to prohibit further collection or use of their student’s personal information in association with the Services, the right to direct us to delete your student’s personal information from our records, and the right to review your student’s personal information. You can contact your child’s Educational Institution for these requests. Parents or guardians may consent to the collection and use of their student’s personal information without consenting to the disclosure of personal information to third parties, other than as necessary for the Services.
RIGHTS OF CALIFORNIA RESIDENTS
The California Consumer Privacy Act (CCPA) grants certain rights to California residents. If our processing of your personal information is subject to the CCPA (whether for Activate Learning’s purposes or on behalf of an educational institution), you are entitled to the following rights:
- Right to access: You have the right to request what personal information we have collected, used, disclosed, and sold about you within the preceding 12 months. You may only make a request for access twice within a 12-month period.
- Right to deletion: You have the right to request the deletion of your personal information that we collect or maintain, subject to certain exceptions.
- Right to opt-out: You have the right to opt-out of the sale of your personal information to third parties. Activate Learning does not have actual knowledge that it sells personal information of minors under the age of 16 years.
- Right to non-discrimination: You have the right to not receive discriminatory treatment if and when you exercise your rights to access, delete, or opt-out under the CCPA.
To exercise your right to access or delete your personal information related to personal information collected and processed on an educational institution’s behalf, you may submit a request to your Educational Institution. Activate Learning will work with the applicable Educational Institution to process and respond to your request.
To exercise your right to access or delete your personal information related to information collected and processed for Activate Learning’s purposes, you may submit a request via email to support@activatelearning.com. When submitting your request to Activate Learning, you must provide us with sufficient information that allows us to reasonably verify you are the person about whom we collected the personal information and describe your request with sufficient detail to allow us to properly evaluate and respond to it. If we are not able to verify your identity for access and deletion requests with the information provided, we may ask you for additional pieces of information. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your personal information. If you are an authorized agent making a request on behalf of another individual, you must provide us with signed documentation that you are authorized to act on behalf of that individual.
RIGHTS OF NEVADA RESIDENTS
If you are a consumer in the State of Nevada, you may request to opt-out of the current or future sale of your personal information. We do not currently sell any of your personal information under Nevada law, nor do we plan to do so in the future. If you have any questions regarding our data privacy practices or would like to opt-out of the future sale of your personal information, please contact us at support@activatelearning.com.
DO NOT TRACK
We do support Do Not Track (DNT). Do Not Track is a preference you can set in your web browser to information websites that you do not want to be tracked.
INFORMATION SECURITY
We implement and maintain reasonable security measures, including access controls and encryption, to protect the information we collect and maintain. However, no security measure or modality of data transmission over the Internet is 100% secure and we are unable to guarantee the absolute security of the personal information we have collected from you.
CHANGES
We may amend this Privacy Policy. We will post the changes to this page and will indicate the date the changes go into effect. We encourage you to review our Privacy Policy to stay informed. If we make changes that materially affect your privacy rights, we will notify you by prominently posting on our Platforms and/or email and obtain your consent if required.
CONTACT
If you have any questions regarding this Privacy Policy, please contact us at:
Activate Learning
44 Amogerone Crossway #7862 Greenwich, CT 06836