Effective Date: July 20, 2021
3. WHO COLLECTS YOUR PERSONAL INFORMATION
Who collects your Personal Information depends on your relationship with LCC or a Partner School.
If you are a student or parent of a student enrolled in a Partner School, your relationship is with that Partner School, and information collected by or shared with that Partner School or provided through LCC’s products and services may be shared with LCC in order for LCC to provide its educational tools and technology.
If you are a Partner School or an administrator at a Partner School, your relationship is directly with LCC. If you are applying to or participating in an online educational program offered directly by LCC (an “Educational Program”), your relationship is directly with LCC.
4. INFORMATION WE COLLECT & HOW WE USE IT
The ways that LCC may collect your Personal Information include:
A. Information You Provide
You may provide certain information directly to LCC depending on your relationship with LCC and the purpose of your visit to the Sites.
(i) Visitors to the Sites (including job candidates, potential direct customers of Educational Programs, potential Partner Schools and others)
(ii) Information Request. If you request information about LCC, including but not limited to information about our Services, we may ask you to provide Personal Information. We will use your Personal Information to send you the information you request and we may also use this information to communicate with you in the future about LCC.
(iii) Newsletters and Other Communications. We may offer newsletters and other communications, online and offline, about LCC, Sites, Services, and promotions. To sign up, we ask you for Personal Information, such as your name, postal address, and email address. We may use the Personal Information you provide to send you the communications you request and to communicate with you about LCC.
(iv) Careers. You may search for open LCC positions on the Sites and apply for positions by submitting your resume and other Personal Information, such as your name, contact information, and job history. We use the Personal Information you submit to evaluate your interest in employment and to contact you regarding possible employment.
(vi) Students or Parents of Students Enrolled in a Partner School or Educational Program
Personal Information: If you are enrolled in a Partner School or Educational Program, you and/or the Partner School in which you are enrolled may provide LCC with a variety of student, parent, and teacher demographic and Personal Information, including but not limited to, full name, physical address, email address, username, password, phone number, birth date, gender, prior educational records, information regarding and guardian information (“Partner Information”). We will use this Personal Information to provide our Services to you.
Information Collected to Facilitate Teaching and Learning Activities: Students enrolled at Partner Schools or in Educational Programs may create or provide a variety of Personal Information during their time as students through the LCC Services. Such information may include media content generated by students and teachers (pictures and audio/video recordings), academic projects, written work, and assessments during school activities and through the use of our teaching and learning tools (“Partner Student-Generated Content”).
(vii) Administrators and Teachers
Registration and Enrollment Information: Partner School, Partner School administrators, and Partner School teachers may provide LCC with a variety of information regarding your school, its student body, and its employees, including Partner Information and Partner Student-Generated Content. We will use this information to provide our Services.
Information Collected to Facilitate School Activities: Administrators and teachers in Partner Schools or Educational Programs may create or provide a variety of information while using our teaching and learning tools. Such information may include media content generated by teachers (pictures and audio/video recordings), academic projects, written work, assessments, and notes concerning student and families during school activities and through the use of our teaching and learning tools.
Financial Information: Partner Schools may provide LCC with a variety of financial information in order to pay for LCC’s Services. Such information may include name, address, and payment information of the Partner School. We will use this information to process your payment.
(viii) Student Work
In connection with our Services to Partner Schools or our Educational Programs, we may provide you with the ability to share your student’s work on external social media websites or other third party websites or platforms; if you choose to share such material outside of our Sites and Services we are not responsible for any further use or disclosure of such materials by such third party websites or platforms or any users thereof.
B. Information We Automatically Collect
We may automatically collect information about the devices you use to interact with our Sites. The information we automatically collect may include device identifier, web browser, search terms and results, page or app views, date and time pages are viewed, language, telephone number, and browsing information collected through cookies and beacons on our Sites, and IP address. We may also automatically collect information about how you use the Sites, such as what you have searched for and viewed on the Sites. The information automatically collected may be associated with any Personal Information you have provided.
(i) Our Purposes in Collecting and Processing the Data We Receive
LCC may use Personal Information for purposes in which we have a legitimate interest. These may include the following purposes:
(ii) To Provide Products, Services, or Information Requested. LCC may use Personal Information about you to fulfill requests for products, Services, or information, including information about potential or future Services, including:
- To manage accounts, and school applications;
- To build a model of student progress and learning in order to provide actionable insight;
- To serve the functions of the Sites;
- To personalize the Sites for your use;
- To personalize the teaching and learning tools for individual students;
- To communicate with you about our products and Services;
- To facilitate your interaction through our Sites with other consumers, including through social networking;
- To respond to questions, comments, and other requests;
- To provide access to and personalize certain areas, functionalities, and features of the Services; and
- To contact you to answer requests for customer support or technical support.
(iii) Administrative Purposes. LCC may use Personal Information about you for its administrative purposes, including to:
- To verify users’ identity and accounts;
- To measure interest in LCC’s Services;
- To process applications;
- To process payment;
- To manage everyday business needs, such as administration and improvement of the Sites;
- To analyze the Sites’ performance and functioning;
- To analyze how you use the Sites and to perform other user research; and
- To develop new products and services.
(iv) Marketing Purposes. Solely as to information collected from visitors to www.learnercentered.org, to send to parents or legal guardians (but not students) further notices, promotions, solicitations, brochures, or other marketing materials regarding our Sites, our Services, and the products and services of our affiliates.
LCC uses Web Technologies and Mobile IDs to collect information about how you use our Sites and Services. Many Internet browsers allow you to block the transmission of information, such as your IP address or location information, or to block the installation of cookies. The Apple iOS and Google Android mobile operating systems also allow you to reset your Mobile IDs or to limit tracking of your Mobile IDs. You may choose to enable these options. However, enabling these options may prevent you from using many or all of the core features and functions available on our Sites.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/ and www.aboutads.info/choices/.
LCC has implemented Google Analytics to collect analytics about how you use our Sites intended for a general audience (but not on the teaching and learning tools). LCC uses the Google Analytics cookie and Google advertising cookies together for retargeting campaigns, to track site behavior, demographic information, and browser and device information, and to personalize content. You can opt-out of Google Analytics using Google’s Ads Settings, or by using the Google Analytics Opt-out Browser Add-on. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
5. INFORMATION WE SHARE
A. We Use Vendors and Service Providers. We may share your information with third-party service providers who perform services and functions on our behalf to support our interactions with you. The types of service providers to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Services. LCC has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
B. Partner Schools. LCC may share Personal Information with Partner Schools for our and their internal business purposes or to provide you with a product or service that you have requested. LCC requires Partner Schools to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and to not use it for any purpose other than the purpose for which LCC provided them.
C. Displaying to Other Users. We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is necessary to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect the rights, property, or safety of you, us, and others; (iv) to enforce LCC’s policies or contracts; (v) to collect amounts owed to LCC; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary.
D. Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may be required to provide your Personal Information as required by a valid legal order to provide information. Before doing so, we will endeavor to confirm that the legal process requesting your Personal Information is valid and enforceable. We may disclose your Personal Information if we reasonably believe it is necessary.
6. BUSINESS TRANSFERS AND CORPORATE CHANGES
We reserve the right to disclose and transfer all information related to the Sites, including Personal Information: (a) to a subsequent owner, co-owner or operator of one or more of our products or services; or (b) in connection with a corporate merger, consolidation, or restructuring, the sale of substantially all of our stock and/or assets, or other corporate change, including, without limitation, during the course of any due diligence process.
7. RIGHTS OF ACCESS, CORRECTION, DELETION, RESTRICTION, AND OPT-OUT
In accordance with applicable law, you may have the right to access, update, correct inaccuracies in, restrict processing of, or delete your Personal Information subject to certain exceptions in applicable law.
In order to stop receiving electronic communications from us, you may unsubscribe to our communications by following the unsubscribe directions included at the end of each email we send.
You may contact us via e-mail at the address provided below. Please include your full name, email address associated with your account, and a detailed description of your data request.
8. DATA RETENTION
9. DATA SECURITY
10. CHILDREN’S PRIVACY
Children enrolled at Partner Schools in the United States may use the Sites provided that the Child’s school has agreed to comply with its obligations under the Family Educational Rights and Privacy Act (“FERPA”) and the Children’s Online Privacy Protection Act (“COPPA”). If an appropriate school or school district official of a Partner School has consented to our collection of information from Children who are students of such Partner School in a manner consistent with COPPA, we will collect and use such Personal Information, but only for the use and benefit of such Partner School and for no other commercial purpose. School officials may revoke at any time their consent to allow Children to use LCC’s products. By enrolling a student in our Educational Programs you are directly consenting to the collection and use of Personal Information from Children who are students in a manner consistent with COPPAand, to the extent applicable, FERPA, but only for the use and benefit of our Educational Programs and Services and for no other commercial purpose
Upon a parent’s or a legal guardian’s request, we will provide a description of the Personal Information we collect, give parents/legal guardians the opportunity to review their Child’s Personal Information or have such information deleted, and provide the opportunity to prevent further collection or use of their Child’s Personal Information. Parents and legal guardians may contact us via email at firstname.lastname@example.org, via mail to Privacy Team / Learner-Centered Collaborative / 49 Stevenson Street / San Francisco, CA 94105, or via phone 866-664-2070.
B. Collection & Use of Information from Children
(i) Collection Practices
The information we may collect on Children, either directly from children using the Services, from parents of students enrolled in our Partner Schools, or legal guardians of applicants to or students participating in our Educational Programs, includes:
- Full name;
- Physical address;
- Email address;
- Username and password;
- Phone number;
- Birth date;
- Guardian information;
- Prior educational records;
- Media content generated by students and teachers (pictures and audio/video recordings) during school activities; and
- Academic projects, written work, notes, and assessments by students, teachers, administrators, and parents.
In addition, we may automatically collect information about one or more devices Children use to interact with our Sites and Services such as a computer, mobile phone, or tablet. The information we automatically collect may include device identifier, web browser, browsing information collected through cookies and beacons, such as IP address, and activity on the Sites, including the date and time of use. Any usage information, device identifier, or other persistent identifier we collect is used for the sole purpose of providing support for the Sites’ internal operations.
(ii) Use of Collected Information
Our tools do not enable Children to make their Personal Information publicly available. We use the information collected on Children to:
- Share students’ progress and school work with teachers and parents or legal guardians;
- Provide reports to teachers or school or school district administrators at the class, school, or district level;
- Support teachers or school or school district administrators implementing or using our Services;
- Monitor the use of our products and perform such analyses as might be necessary or helpful in improving product performance, efficiency, and security; and
- Research how students use the Sites and Services and perform analysis directed at improving the educational effectiveness of our products and services.
We will not use any information collected about Children to directly advertise or market to students or their parents.
(iii) Disclosure of Information from Children
We do not provide links to external resources or chat rooms except for external resources designed for classroom use, such as links to curriculum or teaching tools, nor do our Services contain any offensive or inappropriate content. As a result, LCC’s products are compliant with the Children’s Internet Protection Act.
11. CALIFORNIA PRIVACY RIGHTS
Pursuant to California Civil Code Section 1798.83(c)(2), LCC does not share your Personal Information with third parties for those third parties’ direct marketing use.
B. Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
|Category||Examples||Collected||Disclosed for a business purpose|
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||YES||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||YES||YES|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||YES||YES|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||NO||NO|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a user’s interaction with a website, application, or advertisement.||YES||NO|
|G. Geolocation data.||Physical location or movements.||NO||NO|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||YES||NO|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||YES||YES|
|K. Inferences drawn from other personal information||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||YES||NO|
Under CCPA, personal information does not include:
- Publicly available information that is lawfully made available from federal, state, or local government records.
- De-identified or aggregated consumer information.
We obtain the categories of personal information listed above from the following categories of sources: Directly and indirectly from activity on the Sites.
C. Use of Personal Information
We may use or disclose the personal information we collect for one or more purposes listed above in the section entitled “Our Purposes in Collecting and Processing the Data We Receive.” We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice and obtaining your consent.
D. Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information from the table above for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category J: Non-public education information.
We may disclose your personal information for a business purpose as described in the section entitled “INFORMATION WE SHARE.”
In the preceding twelve (12) months, we have not sold any personal information within the meaning of CCPA.
E. Your Rights and Choices
The CCPA provides certain consumers (defined as California residents or employees) with specific rights regarding their personal information. This section describes California consumers’ rights under CCPA and explains how to exercise those rights.
(i) Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources from which the personal information is collected.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share personal information.
- The specific pieces of personal information we have collected about you.
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
– The category or categories of the personal information sold, or if we have not sold your personal information, we will disclose that fact; and
– The category or categories of the personal information it has disclosed for a business purpose, or if we have not disclosed the personal information for a business purpose, we will disclose that fact .
(ii) Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies as described below.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service that requested by the consumer, take actions reasonably anticipated by the consumer within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Help to ensure security and integrity to the extent our use of your personal information is reasonably necessary and proportionate for those purposes.
- Debug to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the ability to complete such research, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us and compatible with the context in which you provided the information.
- Comply with a legal obligation.
(iii) Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Calling us at 866-664-2070
- Emailing email@example.com
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
(iv) Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a reasonable fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through the use of or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
12. LINKS TO OTHER WEBSITES
13. HOW WE PROTECT PERSONAL INFORMATION
We maintain administrative, technical and physical safeguards to protect against loss, misuse or unauthorized access, disclosure, alteration or destruction of the information you provide when visiting or using the Sites.
14. HOW TO CONTACT US
49 Stevenson Street, Suite 1000
San Francisco, CA 94105