Edfinity is deeply committed to protecting the privacy of user records and any personal information provided in connection with all aspects of the authoring, assessment, online academic competitions and accompany preparatory courses, and content distribution & delivery service (the “Service”) made available at Edfinity.com (the “Site”).
- Edfinity is committed to protecting the privacy of its users. Edfinity will not violate the privacy rights of students as established by the federal Family Educational Rights and Privacy Act (FERPA).
- All student personal information is stored using industry-standard security techniques to minimize the chance that unauthorized individuals would have access to the data. Login information (username, institution name, and password) is encrypted before being sent over the Internet.
- Edfinity uses Internet "cookies" to identify users while they are logged into the Service. Once a user logs out of the Service, the cookie is deleted. The Service will not be functional unless you accept use of Internet cookies.
- Edfinity gathers and analyzes information about our users as a group in order to continue to improve the Service. This information never identifies a specific user.
- Edfinity will not give, sell, rent, loan, or otherwise disclose your personal information, except when we have your permission, are required to by law, or have a reasonable need to protect the rights, property, or personal safety of Edfinity, its users, or the public, as further explained below.
Edfinity makes the Service available to educators and/or students and/or their parents for online academic competitions, preparatory courses, homework, quizzes, and tests through paid subscription for specified courses and time durations. The purpose of the Service is to provide educators with a secure environment to assess student performance and, at their discretion, assign grades, enroll students in academic competitions, and for students to participate in academic competitions and develop their problem solving and critical reasoning skills.
Students provide their username, institution name, and password when logging on to the Service to access and download problem sets, and (in some cases) complete problem sets in Edfinity. The login information is required to determine which assignment should be delivered and who should receive credit for the submission. All login information is sent from your computer to Edfinity’s server as encrypted data.
Student usernames are typically provided to Edfinity by an authorized educator. Users should change their passwords before starting to use the Service to prevent unauthorized access to their respective accounts and problem sets. In some cases, students may create their own username and password.
An educator using the Service may create or import a class roster that includes the student's full name, username, initial password, student number (optional), and e-mail address (optional). The educator may use this information to identify and communicate with students about their problem sets. Students may also add their e-mail address to their account through the Service.
Student records in the Service are intended for use by the student and the student's course educator in compliance with existing laws regarding privacy of grades. Educators have access to student submissions and the associated time and IP address. All student personal information is stored on servers at a location designed specifically to prevent unauthorized individuals from accessing the server or its data. Educators who wish to use the Service provide Edfinity with their full name, email address, institution address, and other information regarding their institution and the courses they teach.
Use and Disclosure of Collected Information
Edfinity will use your personal information to provide the Service to you, alert you of new Service features and enhancements, respond to your support issues, and/or notify you of upgrade opportunities, promotions, and special offers. You agree that we may communicate with you via email and similar technologies for any purpose relating to the Site or the Service.
The use of student information in the Service beyond the purposes of providing assessment falls under the discretion of the educator. Edfinity recommends prior disclosure by the educator to their students of any other intended uses, such as research.
Edfinity administrative responsibilities include "access to" but not "publication of" student records in individually identifiable ways. Edfinity accesses student information for backup, internal maintenance, improvement of the Service, and technical support for educators. If Edfinity accesses student information, it is to troubleshoot the Service or to respond to an educator's question. We take the utmost efforts to not divulge student information to unauthorized individuals. We strive to ascertain whether authorized persons are able to access the information correctly and to inform educators how to access it.
Edfinity may use aggregate information to determine the demographics of our users and to distribute statistics and general marketplace information about Edfinity. These demographics will always represent aggregate information and will not identify a specific user.
Edfinity may also disclose personal information:
- when we have your permission to do so; or
- to companies who work for Edfinity to provide one or more parts of the Service or that provide related administrative functions (such as support services, web analytics, and fraud detection). These third parties may have access to your personal information; if they do, this access is only so that they may perform these tasks on our behalf and they are obligated not to disclose or use it for any other purpose; or
Children under the age of 13 (16 in the European Union)
"Child" refers to any person under the age of 13 (or 16 in the European Union). We may collect from children:
(a) An email address that may be used by us to communicate directly with the child. This email address is never made available to any other user of the site, nor to any third party.
(b) A username used to uniquely identify each child. This username may be disclosed on our website, for example in our message boards, online classroom, or any other part of the site on which the child may participate. Other members of the website may use the child's username to directly contact the child (for example, by private message or in online classroom discussions).
(c) We may ask the child to provide his or her real name. The child's name will only be used for internal purposes, or will be disclosed only to third parties to whom the child has given specific authorization, for example a teacher at the child's school who has requested access from the child to view the child's online school reports. Such third parties must request permission from us before they request this information from the child, and we make a reasonable effort to determine if the third party's request is legitimate before granting such permission. The child's real name will never be made publicly available on our website by us.
(d) Other non-identifying data may be collected in the course of a child's participation on the website; for example, online homework submissions, live classroom discussions, etc. These data may be combined or associated with the child's username, and may be publicly available on the site.
(e) Children using our site may have the opportunity to post personal information about themselves (for example, in a message board post or on a blog or in our online course). Such information may be publicly displayed on the website alongside the child's username. Although we strongly discourage such divulgence of personal information, we cannot prevent it.
1. Parental rights and responsibilities
We do not collect personal information from a child, except as noted below, until we have received verifiable parental consent in accordance with COPPA. The exceptions are:
- An email address is collected from a child at the time of registration, solely to contact the child's parent in order to obtain the necessary parental consent; and
- A username is selected by the child; however, this username cannot be used to contact the child, nor be used for the purposes listed in sections (c) and (d) of item #1 above, unless and until we receive verifiable parental consent.
- At any time, a parent can review or ask us to delete a child's personal information, or can refuse to permit its further collection or use, by contacting us by any of the means listed below.
We provide you the opportunity to opt-out of receiving certain communications from us, by emailing us at firstname.lastname@example.org. In addition, all marketing e-mails from Edfinity will provide you with the opportunity to unsubscribe from future marketing mailings. Even if you opt out of such mailings, however, we reserve the right to send you e-mail and other communications to disclose maintenance and other service-related issues.
Access to Account
If you are a registered user of the Service, you can change your account information through the account profile component of the service. You may need to supply certain information so that we can try to verify that you have authority to modify this information.
The Site may contain links to other Internet sites. We have no responsibility for the privacy practices of other web sites, including the web sites of our advertisers or business partners.
The fact that we may link to a website or present an advertisement is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data, or solicit personal information from you. Other websites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.
We intend to protect your privacy to the fullest extent possible as described in this policy while also fulfilling our responsibility to uphold all applicable laws and regulations. Due to potential legal requirements and other possible circumstances, we cannot ensure that all of your private communications and other personally identifiable information will never be disclosed or accessed in ways not otherwise described in this policy. We may be compelled under law to disclose information to government or third parties under certain circumstances or third parties may unlawfully intercept or access transmissions or private communications. Further, we can, and you hereby authorize us to, disclose any information to law enforcement or other government officials that we, in our sole discretion, believe necessary or appropriate in compliance with the law and/or government requests.
We have implemented reasonable and industry standard security measures on the Site to help protect against the loss, misuse, and alteration of the personal information under our control. Additionally, Edfinity takes reasonable steps to ensure that our third party business partners, including our hosting partners, provide sufficient protection for personal information.
You acknowledge that no method of transmission over the Internet, or method of electronic storage, is 100% secure, and that we cannot guarantee absolute security. If you have any questions about security on our Site and Service, you may contact us. We will promptly make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored "personal data" (as defined in applicable state laws on security breach notification) to you via email or conspicuous posting on the Site.
In no event will Edfinity violate the federal privacy rights of students as established by the Family Educational Rights and Privacy Act (FERPA) at 20 U.S.C. 1232g and 34 C.F.R. part 99.
For this GDPR section, we use the terms "Personal Data" and "processing" as they are defined in the GDPR, but "Personal Data" generally means information that can be used to individually identify a person, and "processing" generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Edfinity will be the controller of your Personal Data processed in connection with the Sites. Note that we may also process Personal Data of our customers' end users or employees in connection with our provision of services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.
What Personal Data Do We Collect From You?
We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Sites.
Information we collect directly from you: We receive Personal Data directly from you when you provide us with such Personal Data, including without limitation the following:
- First and last name
- Email address
- Mailing address
- Telephone number
- Facts about education history and career
- General location
Information we receive from third party sources: Some third parties such as our business partners and service providers provide us with Personal Data about you, such as the following:
- Account information for third party services: If you interact with a third party service when using our Sites, such as if you use a third party service to log-in to our Sites (e.g., Facebook, Google, or Twitter), or if you share content from our Sites through a third party social media service, the third party service will send us information about you, such as information from your public profile, if the third party service and your account settings allow such sharing. The information we receive will depend on the policies and your account settings with the third party service.
Information we automatically collect when you use our Sites Some Personal Data is automatically collected when you use our Sites, such as the following:
- IP address
- Device identifiers
- Web browser information
- Page view statistics
- Browsing history
- Usage information
- Transaction information (e.g. transaction amount, date and time such transaction occurred)
- Location inferred from your IP address
- Log data (e.g. access times, hardware and software information)
We process Persona Data to operate, improve, understand and personalize our Sites. For example, we use Personal Data to:
- Create and manage user profiles
- Communicate with you about the Sites
- Process orders
- Contact you about Site announcements, updates or offers
- Provide support and assistance for the Sites
- Personalize website content and communications based on your preferences
- Meet contract or legal obligations
- Respond to user inquiries
- Fulfill user requests
- Comply with our legal or contractual obligations
- Resolve disputes
- Protect against or deter fraudulent, illegal or harmful actions
- Enforce our Terms and Conditions
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our "legitimate interests" or the legitimate interest of others, as further described below.
- Contractual Necessity: We process the following categories of Personal Data as a matter of "contractual necessity", meaning that we need to process the data to perform under our Terms and Conditions with you, which enables us to provide you with the Sites. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Sites that require such data.
- First and last name
- Email address
- Mailing address
- Telephone number
- Facts about education history and career
- General location
- Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.
- First and last name
- Email address
- IP address(es)
- Examples of these legitimate interests include:
- Operation and improvement of our business, products and services
- Marketing of our products and services
- Provision of customer support
- Protection from fraud or security threats
- Compliance with legal obligations
- Completion of corporate transactions
- Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
- Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
- Payment processors
- Ad networks
- Analytics service providers
- Services to provide customer support
- Hosting service providers
We also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include:
- Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Sites)
- Social media services (if you interact with them through your use of the Sites)
- Other parties authorized by you
We also share information with third parties when you have given us consent to do so (as indicated at the point such information is collected).
We also share Personal Data when we believe it is necessary to:
- Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies
- Protect us, our business or our users, for example to enforce our Terms and Conditions, prevent spam or other unwanted communications and investigate or protect against fraud
- Maintain the security of our products and services
- Provide a service directly authorized and requested by you, the end user
Furthermore, if we choose to buy or sell assets, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party, and we would share Personal Data with the party that is acquiring our assets. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.
How Long Do We Retain Your Personal Data?
We retain Personal Data about you as long as you have an open account with us or as otherwise necessary to provide you Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.
What Security Measures Do We Use?
We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity. For example, we encrypt all data in-transit, obfuscate and anonymize data that we share with processors like analytics services, and maintain all services with security patches in a timely manner. We also require that our suppliers protect such information from unauthorized access, use, and disclosure.
Personal Data of Children
We do not knowingly collect or solicit Personal Data from anyone under the age of 16. If you are under 16, please do not attempt to register for the Sites or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Data, please contact us at email@example.com
What Rights Do You Have Regarding Your Personal Data?
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email firstname.lastname@example.org Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
- Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access your Personal Data by visiting Account settings > Your data (coming soon).
- Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. In certain circumstances, you can correct some of this information directly by either updating directly in the relevant Account settings pane or emailing us directly email@example.com
- Erasure: You can request that we erase some or all of your Personal Data from our systems.
- Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Sites.
- Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
- Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes.
- Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
- Right to File Complaint: You have the right to lodge a complaint about Edfinity's practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.
If you have any questions regarding this privacy statement, please email or write to:
Looking Glass Ventures, LLC
PO Box 60369
Palo Alto, CA 94306