ISA Learning, Inc. (“ISA Learning”, “we”, “us”, “our”) is dedicated to providing an innovative set of educational curricula, assessments, and services for educational institutions that focus on improving 21st century skills such as collaboration as well as STEM skills (Science, Technology, Engineering and Math) such as problem solving with the engineering design cycle.
WHAT IS “PERSONALLY IDENTIFIABLE INFORMATION”?
Personal information does not include “aggregate” information. Aggregate information is data we collect about a group or category of products, services or users, from which individual user identities have been removed. In other words, information about how you use a service may be collected and combined with information about how others use the same service. Aggregate data helps us understand trends and our users’ needs so that we can better consider new features or otherwise tailor our Services.
PRIVACY PRACTICES FOR STUDENTS UNDER 13 YEARS OLD
ISA Learning is a tool used by teachers, schools, school districts, parents and students meant for classroom use; guided classroom exercises; and out of classroom, teacher guided exercises. In some instances, student participants may be under thirteen years of age. ISA Learning takes children’s privacy very seriously. It is ISA Learning policy to prohibit the collection of information from children under 13 until we first obtain consent from the child’s parent/legal guardian or through the child’s school or teacher.
How Does ISA Learning Obtain Parental Consent?
The Children’s Online Privacy Protection Act (COPPA) and Family Education Rights and Privacy Act (FERPA) requires us to obtain parental consent from a child’s parent or legal guardian before we can collect personal information from children under 13 years of age. Therefore, we only collect personal information through the Services from a student under 13 where that student’s school, district, or teacher has agreed to obtain parental consent for that child to use the Services and disclose personal information to us. Our Terms of Service explains more about the parental consent process.
If we discover that we are collecting information from students under 13 years old without parental consent, we will permanently delete this information as quickly as we can. If you believe that a student participant under the age of 13 has violated our policy and may be participating in the ISA Learning Services without parental consent, please notify us immediately at firstname.lastname@example.org.
If you are a teacher, school, or school district, by using ISA Learning Services, you warrant that you have the authority to act on behalf of the entity for which you purport to act and have the authority to bind said entity into a contractual relationship. This authority will be used in lieu of a paper permission slip.
What is the ISA Learning Policy for Account Creation?
A designated school administrator or teacher will be in charge of creating Student Accounts for ISA Learning Services for his or her classroom once parental consent is obtained. Students will not be able to create a ISA Learning account on their own behalf. Parents and guardians should always consult their school’s Acceptable Use policies and practices for protecting their children on the Internet.
Teacher and Administrator Accounts: Moderator Tools
In addition to the ability to create student accounts, Teacher and Administrator accounts registered with ISA Learning are also able to monitor and moderate all student content associated with his or her own classroom.
Can I View My Child’s ISA Learning Information?
Absolutely! As a parent or guardian of a student under 13 years old, you have the ability to request information from ISA Learning regarding the type of data being collected, view your child’s information and online activity, and, if you choose, request that we delete and/or stop making further use of your child’s information. ISA Learning adheres to all applicable state and federal law, including FERPA, relating to parent and student rights to education records.
For more information on how to do this, please contact email@example.com.
WHAT INFORMATION DOES ISA LEARNING COLLECT?
Because of the interactive nature of the ISA Learning Services, we collect different types of information that come from a variety of sources. The following section explains the types of information the ISA Learning Services collect (including from children under 13 years of age).
Information that You Provide
1. USERNAME REGISTRATION INFORMATION
Schools, Teachers, and Administrators
We may collect the following personal information when a School, Teacher, or Administrator creates a ISA Learning username:
- First and Last Name
- Email Address
- Class Name
- School Name
Students (Including Students Under 13)
A School, Teacher, or Administrator will create Student Accounts on the student’s behalf for each student that receives parental consent to use ISA Learning.
ISA Learning may collect the following personal information to create each Student Account:
- First and Last Initial of Student
- Class name
2. USER-GENERATED CONTENT (“USER POSTS”) BY STUDENTS (INCLUDING STUDENTS UNDER 13)
Once an ISA Learning student account is created by a teacher, ISA Learning allows Student Accounts (Including Students under 13 with necessary consent) to create and share user-generated information (“User Posts”) in an online or app-based setting.
The types of user-generated content that ISA Learning permits are:
- Short, text-based messages
Before students’ can post User Posts to the ISA Learning Services, it is very important to review our Terms of Service for guidelines on the acceptable use of the ISA Learning services. Violations of the ISA Learning Terms of Service are taken very seriously, and may be grounds for suspension or deletion of a user account.
Information We Collect Automatically
There are some types of information that are collected automatically every time a user accesses the ISA Learning Services. This automatic collection also applies to all user accounts, including Student Users under 13 years old with appropriate consent to use the Site.
Our Services provide the ability to log into user accounts in a password-protected setting. ISA Learning records details of user activity on the Services, including the frequency of Services usage, operating systems and browsers used and IP addresses.
Our Services also implement “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a website server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.
One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you register with our Services, a cookie helps ISA Learning recall your specific information on subsequent visits. When you return to our Services, the information you previously provided can be retrieved, so you can easily use the ISA Learning features that you customized.
You have the ability to accept or decline cookies. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. It’s also important to note that we do not allow third party behavioral tracking
HOW DOES ISA LEARNING USE COLLECTED INFORMATION (INCLUDING INFORMATION FROM STUDENT USERS UNDER 13)?
The information that you provide to ISA Learning will be securely stored and used to assess learning in our programs and to facilitate instruction. We also may use this information in aggregate form to publish results of our research. Information we collect may also be used for marketing purposes. Any information ISA Learning shares publicly will be stripped of any personally identifiable information (“PII”) in accordance with U.S. privacy laws and information security, as discussed in detail below.
The information we automatically collect enables ISA Learning to improve the design, content and internal performance of our Services. We also may use this information in aggregate form in order to analyze site usage and the popularity of our Services.
DOES ISA LEARNING SHARE PERSONAL INFORMATION (INCLUDING INFORMATION FROM STUDENTS UNDER 13) WITH OTHER PEOPLE?
ISA Learning respects the privacy of all participating students (including students under 13), teachers, and schools, and will not sell, rent, or purchase any Personal Information collected during the use of ISA Learning Services.
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information unless we provide you with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential.
However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
We will also transfer or otherwise disclose personal information in response to judicial process, to comply with legal requirements, and, as permitted under provisions of law, to provide information to law enforcement agencies or in connection with an investigation on a matter related to public safety. We may also use your information as permitted by law to protect our rights or property, the ISA Learning Services, or its users.
Our Service Providers provide support for the internal operations of ISA Learning Services and are required not to disclose this information to any other third party who is not a Service Provider for any purpose.
SECURITY OF YOUR PERSONAL INFORMATION
ISA Learning secures your personal information (including personal information from Students under the age of 13) from unauthorized access, use or disclosure through a username and password. ISA Learning secures the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted.
We implement a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of your personal information.
No data transmission over the Internet even if encrypted can be guaranteed to be private. As a result, while we strive to protect your personal information, ISA Learning cannot ensure or warrant the security of any information you transmit to us, and you transmit such information at your own risk. Further, your account information is protected by a password for your privacy and security. It is up to you to protect against unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your account.
THIRD PARTY WEBSITES
ISA Learning is not responsible for the policies, content, and practices of third-party websites to which the Services may link. Please refer to these sites’ privacy policies to learn how they collect and use personal information.
Fair Information Practices
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
- We will notify the users via email within 1 business day of discovery of the breach
- We will notify the users via in site notification within 1 business day of discovery of the breach.
CAN SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
If at any time you would like to unsubscribe from receiving future emails, you can email us at firstname.lastname@example.org and we will promptly remove you from ALL correspondence.
If ISA Learning materially changes the way that it collects, uses or discloses Personal Information, we will notify users via email. In the event that ISA Learning materially changes the way that it collects, uses, or discloses Personal Information of students under 13, we will notify parent(s) or guardian(s) or school account administrator(s) via email.
A FINAL NOTE TO PARENTS/GUARDIANS REGARDING USER POSTS
While ISA Learning provides an online learning environment meant for educational use, it is still a service that is provided on the Internet. As with every internet-based service, it is important to be aware of your surroundings and about the information you post online. ISA Learning encourages parents to stress the importance of and talk about online safety with their children.