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CollegeSpring Services Privacy Policy

Last Updated: March 14, 2023

CollegeSpring, Inc. and its affiliates (“CollegeSpring,” “we,” “our,” and/or “us”) value the privacy of individuals who use our applications, and services that link to this privacy policy, including but not limited to our Learning Management System (“LMS”) (collectively, our “Services”).  This privacy policy (the “Privacy Policy”) explains how we collect, use, and share personal information from or about CollegeSpring users or their devices.

By using our Services, you agree to the collection, use, disclosure, sharing, and procedures this Privacy Policy describes.  Beyond the Privacy Policy, your use of our Services is also subject to our Terms of Use (https://collegespring.org/services-terms-of-use/).  When you use our Services on behalf of one of our customers (each a “Customer”), we may process the information you provide to us in connection with such use in accordance with separate contractual terms between us and the applicable Customer.

INFORMATION WE COLLECT

We may collect a variety of information from or about you or your devices from various sources, as described below.

  1. Information You Provide to Us

Registration and Profile Information.  When you register to use our Services, we collect personal information provided by students and teachers to their school, which includes their name, username, email address, phone number, login password, and school affiliation if the user is a teacher, administrator, or student.  This information is used to facilitate educational activities between students and teachers on our Services.

Student Information.  When you use our Services as a student, we may collect personal information from you, such as your first name, last name, email address, school ID number, school enrollment, grade, student status (e.g., returning, new, or dropped), practice test scores, official test scores (e.g., SAT, ACT, TSIA2), and demographic information such as gender, race, ethnicity, English language learner status, and free/reduced price lunch status.  We collect this information to provide you with our Services and to analyze and improve our programs.

Communications.  If you contact us directly, we may receive other personal information about you.  For example, when you contact us for support, we will receive your name, email address, the contents of a message or attachments that you may send to us, and other information you choose to provide.  If you subscribe to our newsletter, we will collect your first name, last name, email address, organization, and how you heard about us.  When we send you emails, we may track whether you open them to learn how to deliver a better customer experience and to improve our Services.

Audio and Video Information.  With your consent, our Services may request access to the camera and microphone on your device.  This information is used to provide our Services to you (e.g., to facilitate video chat engagements between CollegeSpring Partner Support team and teachers).

Surveys.  We may conduct surveys to improve our Services and assess student and teacher satisfaction.  If you choose to participate in a survey, we may collect personal information related to your education, race, ethnicity, gender, and other personal information related to your experience in connection with our Services.

  1. Information We Collect When You Use Our Services

Location Information.  When you use our Services, we may receive your location information (for example, your IP address may indicate your general geographic region).  We may also collect your general location information when you choose to take part in a survey.

Device Information.  We receive information about the device and software you use to access our Services, including internet protocol (IP) address, operating system version, phone carrier and manufacturer, application installations, device identifiers, mobile advertising identifiers, and push notification tokens.

Usage Information.  To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, like the pages or other content you view or download, the surveys in which you take part, and the dates and times of your visits.

Information from Cookies and Similar Technologies.  We and third-party partners collect information using cookies, pixel tags, or similar technologies.  Our third-party partners, such as analytics partners, may use these technologies to collect information about your online activities over time and across different services.  Cookies are small text files containing a string of alphanumeric characters.  We may use both session cookies and persistent cookies.  A session cookie disappears after you close your browser.  A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services.

Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings.  Please note that if you delete or choose not to accept cookies from our Services, you may not be able to utilize the features of our Services to their fullest potential.

  1. Information We Receive from Third Parties

Third Parties.  We may receive additional personal information about you from third parties and combine it with other information we have about you.

HOW WE USE THE INFORMATION WE COLLECT

We use the personal information we collect:

  • To track program outcomes and user engagement, and provide information to our funders;
  • To provide, maintain, improve, debug, support, and enhance our Services;
  • To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;
  • To send you SMS messages and push notifications;
  • To personalize your experience on our Services such as presenting tailored content;
  • To generate de-identified and aggregated data and use it for any lawful purpose;
  • To find and prevent fraud, and respond to trust and safety issues that may arise;
  • For compliance purposes, including enforcing our Terms of Use or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
  • For other purposes for which we provide specific notice at the time the information is collected.

HOW WE SHARE THE INFORMATION WE COLLECT

Affiliates and Subsidiaries.  We may share any information we receive with our affiliates or subsidiaries for any of the purposes described in this Privacy Policy.

Vendors and Service Providers.  We may share information received with third-party vendors and service providers who assist us in providing our Services, such as Agilix, Salesforce, and Google Suite.  These providers may access and process data on our behalf and may use cookies or other tracking technologies.  You acknowledge that their use of your information will be governed by their own privacy policies and settings, and we encourage you to review them.

Funders.  We may share any information we receive with our funders to comply with reporting obligations and to enable them to assess the effectiveness of our programs.

Teachers and Administrators.  We may share information, such as aggregate test data and survey responses, with teachers and administrators for the purpose of assessing program effectiveness and monitoring progress.

Sharing Between Users.  We facilitate the sharing of information between users of our Services, which may require the disclosure of certain information, including personal information, to other users.

API Data Transfer.  Upon your request, we may share information with other systems via API data transfer.  For instance, schools subscribed to our “Publish Anywhere” feature can use the Learning Tools Interoperability integration to transfer data in or out of their non-Agilix LMS system.  Furthermore, as part of providing our Services, we may transfer data to other platforms such as Salesforce.

Marketing.  We do not rent, sell, or share information about you with nonaffiliated companies for their direct marketing purposes unless we have your permission.

Analytics Partners.  We use analytics services such as Google Analytics and Mixpanel to collect and process certain analytics data.  These services may also collect information about your use of other websites, apps, and online resources.  You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

As Required by Law and Similar Disclosures.  We may access, preserve, and disclose your personal information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety.  For the avoidance of doubt, the disclosure of your personal information may occur if you post any objectionable content on or through the Services.

Merger, Sale, or Other Asset Transfers.  We may disclose and transfer your personal information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our business or assets.

Consent.  We may also disclose personal information from or about you or your devices with your permission.

YOUR CHOICES

Do Not Track.  There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.

Communications.  If you no longer wish to receive email or SMS communications from us, you can opt out at any time by clicking the unsubscribe link or following the instructions in the SMS messages.  Even if you opt out of receiving email and SMS messages from us, you will continue to receive administrative messages related to your account and services from us.

If you choose not to provide us with information we collect, some features of our Services may not work as intended.

THIRD PARTIES

Our Services may contain links to other websites, products, or services that we do not own or operate (“Third-Party Services”).  We are not responsible for the privacy practices of these Third-Party Services.  Please be aware that this Privacy Policy does not apply to your activities on these Third-Party Services or any information you disclose to these Third-Party Services.  We encourage you to read the privacy policies of these Third-Party Services.

SECURITY

We make reasonable efforts to protect your personal information by using physical and electronic safeguards designed to improve the security of the personal information we maintain.  However, as our Services are hosted electronically, we can make no guarantees as to the security or privacy of your personal information.

CHILDREN’S PRIVACY

We do not knowingly collect, maintain, or use personal information from children under 13 years of age (“Minors”), and no part of our Services are directed to Minors.  If you learn that a Minor has provided us with personal information in violation of this Privacy Policy, then you may alert us at [email protected].

INTERNATIONAL VISITORS

Our Services are hosted in the United States and intended for visitors located within the United States.  If you choose to use our Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing.  Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating our Services.  By providing any information, including personal information, on or to our Service, you consent to such transfer, storage, and processing.

UPDATE YOUR INFORMATION

If you are a teacher or administrator, you can update your account and profile information by making a request to CollegeSpring Partner Support.  If you are a student, you can update your information in the LMS or contact your school administrator for assistance.

CHANGES TO THIS PRIVACY POLICY

We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted.  If we materially change the ways in which we use or share personal information previously collected from you through our Services, we will attempt to notify you through our Services, by email, or other means.

CONTACT INFORMATION

If you have any questions, comments, or concerns about our processing activities, please email us at [email protected].

CollegeSpring, Inc.

1990 N California Blvd, Suite 20

Walnut Creek, CA 94596