Updated and Effective: October 31, 2022
The Learning Platforms include teaching and learning resources designed for students in pre-K through college. Typically students will access the Learning Platforms through agreements Carnegie Learning has with teachers, or representatives of schools, learning institutions, school districts, state or local boards of education or other educational organizations (collectively, “Schools”).
The Learning Platforms are made available to students and others authorized by the Schools, who have been provided access by the Schools, such as by adding a student’s name and email address to their class roster or by syncing class rosters through third-party services authorized by a School. Teachers or administrators may also provide other information to us about their students who participate in the Learning Platforms. We may also disclose information to the Schools pursuant to our agreements with the Schools. When we provide access to the Learning Platforms through a School agreement, we collect, process, disclose, and store student information in order to provide learning services through the Learning Platforms and on behalf of Schools and only in the ways permitted by the applicable School agreement. We otherwise use information as set forth in this policy.
Certain students may obtain access through Private Providers. If you are accessing the Learning Platforms through a Private Provider, please see below for additional information.
Students Younger than 13
Some students that access our Learning Platforms may be younger than the age of 13 (“Children”) and the online collection of personal information from those students may therefore be subject to the Children’s Online Privacy Protection Act (“COPPA”) and other applicable law. Carnegie Learning collects personal information about Children for the use and benefit of Schools, and for no other commercial purpose. When a School provides access to the Learning Platforms to students who are Children, the School represents that it has secured all necessary consent from the parents of those Children or is providing that consent on the parents’ behalf. We limit the use of information about Children to the educational context authorized by the contracting School. If you are the parent of a Child who uses our Learning Platforms through his/her/their School and have questions about our privacy practices, please contact us as indicated in the “Contact Us” section below.
What Information Do We Collect from Students?
Information collected directly from students
Carnegie Learning may ask you to provide certain information to us directly, depending on which product(s) you are using, including:
Information collected automatically through use of the Learning Platforms
In addition to any personal information that you choose to submit to the Learning Platforms, we and our third-party service providers may use a variety of technologies that automatically or passively collect certain information whenever you visit or interact with the Learning Platforms ("Usage Information"). Usage Information may include the following, among other information:
Any Usage Information, Device Identifier, or other persistent identifier we collect is used for the sole purposes of providing our Learning Platforms to students and their Schools and to support the Learning Platforms’ internal operations.
The technologies that may be used to collect Usage Information include the following:
For more information on cookies, visit http://www.allaboutcookies.org.
Web Beacons. We may use web beacons (small graphic images or other web programming code, also known as "1x1 GIFs" or "clear GIFs") and similar technologies on our Learning Platforms. Web beacons can recognize certain types of information on your computer such as cookies, the time and date a page is viewed, and a description of the page where the web beacon is placed. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Learning Platforms, to monitor how users navigate the Learning Platforms, to count how many e-mails that were sent were actually opened or links were actually viewed and to improve your experience on the Learning Platforms.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Learning Platforms, such as the links you click on. The code is temporarily downloaded onto your device from our web server or a third party service provider, is active only while you are connected to the Learning Platforms, and is deactivated or deleted thereafter.
In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes.
Information We Receive from Schools
How Does Carnegie Learning Use Information Collected about Students?
Carnegie Learning will not use any information collected about students to advertise or market to students or their parents.
To And On Behalf Of Schools
As discussed above, we provide the Learning Platforms to students through agreements with Schools and on behalf of those Schools. Accordingly, Schools (and those who obtain authorized access from the Schools)
and have access to all of the information we collect via registration and the Learning Platforms from students associated with that School.
In some cases, a School (including teachers or administrators) may enter into additional reporting or research agreements for the provision of reports or analyses that require data to be associated with demographic categories (gender, ethnicity, free or reduced lunch status, etc.) or other individual student information, such as test scores. In such cases, the teachers, Schools and/or school district administrators provide Carnegie Learning and specified service providers with the information required, which may personally identify students. When such agreements are in place, reports containing student information are provided only to the teachers, Schools and school district administrators authorized to receive that information. In such cases, data is held securely and only Carnegie Learning employees and service providers directly involved in producing these reports have access to students’ personal information.
In order to provide and support our products, Carnegie Learning may contract with third parties and share information required to carry out these services with these third parties. These service providers provide support services, such as hosting the Learning Platforms and operating their features, or performing other administrative services. In such cases, all third parties are required to abide by this policy. Carnegie Learning takes reasonable steps to release personal information collected from students only to service providers and third parties who are capable of and have agreed to maintain the confidentiality and security of that information and to use that personal information only to provide the applicable service to us or on our behalf. You may view a list of our current service providers here: Link
Administrative and Legal Reasons
Research and Statistical Purposes
Carnegie Learning uses de-identified and aggregate data about students’ use of our Learning Platforms for product development, research or other purposes. To de-identify data, we remove all direct and indirect personal identifiers. These identifiers include, but are not limited to, name, ID number, birth date, teacher name, class and school identifications. Carnegie Learning agrees not to attempt to re-identify any de-identified data, and to restrict any third parties to whom it discloses such data from attempting to re-identify any de-identified data. We may store de-identified data indefinitely. Schools, school districts, and individuals may ask for their data to be excluded from any de-identified data sets. To request such exclusion, please email [email protected].
In connection with research studies, Carnegie Learning and/or its partners may publish or discuss aggregate data about student performance and results. Such publications never reference individual information, only aggregate statistics. Research projects that make use of student data may be reviewed by an Institutional Review Board (IRB) which is responsible for approving the goals and procedures of the study, including those related to maintaining privacy of information. The IRB may or may not require parental or student notification or approval. Schools or school districts provide prior consent to any research that involves interaction with the schools and their students’ information. Carnegie Learning is committed to abiding by IRB recommendations and requirements.
As part of our commitment to continual improvement, Carnegie Learning may field test new application content and test versions of features within our products, including through studies which employ random assignment. We may also partner with third-party researchers to conduct such research. If the research is not exempt from IRB review, an Institutional Review Board (IRB) will review the goals and procedures of the study, including those related to maintaining privacy of information.
Sweepstakes, Contests, and Promotions
Third-Party Analytics Services
We may work with analytics providers to provide us with information regarding the use of our Learning Platforms. These third parties may set and access their own tracking technologies on your devices (including cookies and web beacons), and they may otherwise collect or have access to information about you, including Usage Information. With respect to Children, to the extent there is any collection of information through tracking technologies, it is used only for providing support for internal operations as needed to provide the Learning Platforms.
Data Retention & Access
You may be able to review, modify, and delete certain information related to your use of our Learning Platforms through your account. Schools may ask to review the information that Carnegie Learning has collected and retained about a particular student, or request its deletion, by contacting us at [email protected]. If you are a parent or student and would like to access or request deletion of any information collected by Carnegie Learning as a result your or your student’s use of our Learning Platforms, please contact your School
Carnegie Learning will retain personal information about students as long as required by our agreement with a School or as required by law. Carnegie Learning may otherwise retain personal information as required by applicable law or its contractual obligations to a School. Carnegie Learning may also delete personal information or other data when requested by a School or as provided under a School agreement. The School may request a copy of the data or that we retain the data on their behalf by emailing their request to [email protected] within 60 days of such notification.
Unless otherwise prohibited by an agreement with a School, Carnegie Learning may retain aggregated, de-identified, or other non-personal data, including curriculum or other content submitted by users when using the Learning Platforms as long as needed for our business purposes.
Carnegie Learning takes commercially reasonable steps to help protect and secure personal information. We have implemented an information security program with numerous measures, including administrative, technical and physical controls that are designed to reasonably safeguard personal information under our control against loss, misuse and unauthorized alteration. However, please remember that no data storage or data transmission over the Internet, or by other means, can be guaranteed to be 100% secure. Thus, while we strive to protect your personal data, Carnegie Learning cannot ensure or warrant the security of any information you transmit to us. Therefore, each School and any student user accessing the Learning Platforms under the School’s authorization understands, acknowledges, and agrees that you transmit personal information to the Learning Platforms at your own risk.
The Learning Platforms may contain links to other web sites or include other content hosted and served by third parties that Carnegie Learning does not control. Likewise, our content, including some of our Learning Platforms, may be provided through or be included on third parties’ web pages and web sites that are not associated with Carnegie Learning and over which we have no control. We may collect Usage Information through Carnegie Learning content appearing on third-party sites. Carnegie Learning is not responsible for the privacy practices of any third party.
Consent to Transfer of Data
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Accessing the Learning Platforms through Private Provider
The Learning Platforms may be made available through agreements we have with organizations who provide specialized education services to students, but who are not directly associated with a School (“Private Provider”). In those cases, we or the Private Provider (rather than the School) will obtain any necessary consent from a student’s parent or legal guardian as required by law.
When students access the Learning Platforms through a Private Provider, Carnegie Learning acts as a service provider on behalf of and in the ways permitted by the agreement with the Private Provider. Accordingly, Private Providers may have access to all of the information we collect from students that is associated with the students’ accounts with the Private Provider. If a Private Provider is working in connection with a student’s School, they may share or ask us to share student information about students associated with that School.
If you are the parent of a Child who uses our Learning Platforms through a Private Provider and have questions about our privacy practices, or would like to request to access or delete your Child’s information, please contact us as indicated in the “Contact Us” section above. If you would like more information about how the Private Provider handles your personal information, please contact the Private Provider.
Information for California Residents
Carnegie Learning collects personal information from users of the Learning Platforms as a service provider on behalf of and only in the ways permitted by the applicable School agreement. Carnegie Learning does not sell personal information collected through the Learning Platforms or share that information with third parties for their own direct marketing purposes. If you are a California consumer and would like to submit a request to access or delete information under the California Consumer Privacy Act (CCPA), please direct your request to your School administrator.