Privacy Policy

 

Last Updated: May 1, 2018

ClassPulse (“CP” or “we” or “us” or “our”) respects the privacy and integrity of any personal information that users (“user” or “you”) provide in the use our Web sites and System, whether You are an institutional user (“Institution”), a student or a professor/instructor (“Faculty”). This Privacy Policy is designed to inform You, as a user of CP Services, about the types of information that CP may gather about or collect from you in connection with your use of the Website. It also is intended to explain the conditions under which CP uses and discloses that information, and your rights in relation to that information.

This Privacy Policy will be continuously assessed against new technologies, business practices and our users’ needs. As we update, expand and diversify our products and services, this Privacy Policy may evolve. Each time you use the Website or Services however, the current version of this Privacy Policy will apply. Accordingly, each time you use the Website you should check the date of this Privacy Policy (which appears at the beginning of this document) and review any changes since the last time you used the Website.

The CP Website and Services are hosted in the United States of America and are subject to U.S. state and federal law. If you are accessing our Website from other jurisdictions, please be advised that you are transferring your personal information to us in the United States, and by using our Website, you consent to that transfer and use of your personal information in accordance with this Privacy Policy. You also agree to abide by the applicable laws of applicable states and U.S. federal law concerning your use of the Website and your agreements with us. Any persons accessing our Website from any jurisdiction with laws or regulations governing the use of the Internet, including personal data collection, use and disclosure, different from those of the jurisdictions mentioned above may only use the Website in a manner lawful in their jurisdiction. If your use of the Website would be unlawful in your jurisdiction, please do not use the Website.

 

BY USING OR ACCESSING THE WEBSITE, YOU ARE ACCEPTING THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY.
 

 

GATHERING, USE AND DISCLOSURE OF NON-PERSONALLY-IDENTIFYING INFORMATION


Application of This Policy

At CP, we are committed to protecting the privacy of our users, which is why we do not sell or rent any personal information (as defined in ‘What is Personal Information’) regarding our users to any third party. We hope this Privacy Policy will answer Your questions regarding how we treat personal information gathered from visitors to our Web sites and users of the CP Services.

What is Personal Information

For the purposes of this Privacy Policy, “personal information” means information or an opinion that identifies a living individual or can be used to identify an individual, including but not limited to Your name, address, e-mail address, country of residence, as well as other information when such information is combined with other information (e.g. name of education institution, student ID, grades, cell phone number). Personal information does not include business contact information (for example, if You are an administrative user on behalf of an educational institution, your email address at the institution might not be deemed personal information except in Australia where this sentence does not apply). Except in Australia, Personal information also does not include “aggregate” information or de-identified information, which is data we collect about and through the use of our Web site and the CP Services and may include anonymized data which does not identify any individuals and cannot be traced back or linked to an identifiable individual. Our privacy policy does not restrict or limit our collection and use of aggregate or de-identified information, or other types of non-personal information.

Consent

You acknowledge and agree that by accessing our Web site, using our mobile applications or using the CP Services more generally You fully understand, accept and voluntarily consent to the collection, use, retention and disclosure of personal information in accordance with this Privacy Policy. It is always Your choice whether or not You provide us with Your personal information; however, a decision to withhold personal information may restrict or prevent us from providing You with a particular product or service including access to any subscriber features of the CP Services. We will only collect, use, and disclose Your personal information in accordance with this Privacy Policy, except where otherwise permitted or required by applicable law or regulatory requirement.


Collection of Personal Information

In order to use certain features of our services You must first complete a registration process and establish an account (“Account”).  During registration for Your Account You will be required to provide basic information such as Your first and last name, educational institution, valid email address for Your educational institution and establish a password (“Account Information”). CP will retain Account Information and associate it with Your Account. 

For students, our servers automatically record information about Your use of the System, such as when You log in and submit answers to questions or provide feedback to the instructor. We will associate that information with their account. Other than account set up information, it is up to the instructors to decide what surveys they wish to use, and therefore which data they collect from students. The instructors may use those data for academic evaluation purposes. We store and maintain personal and associated account information in order to provide the System.

CP may conduct statistical analyses on students’ data and performance to study the effectiveness of the CP Services and increase in-class learning. No identification of users will be revealed at any point to any third party. We do not sell, rent, trade or otherwise disclose personal and associated account information about our users.

Use of Your Personal Information

You acknowledge that CP may use personal information that You voluntarily disclose to us to:

  1. Provide Institution/Faculty with information about new products, services, newsletters, informative e-mails, and research on future product ideas or improvements (and, by using the CP Services, You
    give Your consent to receive such information);

  2. Assist us in creating, improving, or providing content that is relevant to You;

  3. Assist us in creating better products and services to meet the needs of Institution/Faculty;

  4. Allow You to purchase and download products, obtain access to the System or otherwise engage in activities You select;

  5. Provide You with technical support;

  6. Help You quickly find software, services or product information important to Institutions/Faculty;

  7. Send transaction-related communications such as welcome letters, and product/service order confirmations.

    While using the CP Services, You may have opportunities to post reviews or other personal information in forums on the Web site at Your own discretion. Please understand that when You post such information, it is made public and is not subject to our control. You should exercise caution when deciding to disclose any personal information in a publicly available forum such as the Web site and agree to indemnify CP for any damages or claims resulting from any of Your postings. CP is not obligated to monitor postings and at its discretion remove any content submitted.

     

Disclosure of Your Personal Information


CP will not sell or rent Your personal information to any other party and will only use and disclose Your personal information for the purposes for which it was collected as described in this Privacy Policy. However, You agree that CP may disclose Your personal information in the circumstances set out below:

  • If You are a student, CP may disclose Your personal information to administrators and instructors at Your academic institution including Your teachers and teaching assistants.
  • CP may be required by law to disclose personal information without Your consent in the event of emergency situations or when required by government, valid legal process, or other legal authority;
  • CP may also disclose Account Information to the administration of any institution (at which You are a professor/instructor) for administrative purposes including the right for the institution to compile a list of instructors who use the Services and contact such instructors in order to obtain references to evaluate an implementation of the Services.
  • CP may also disclose personal information to third parties in connection with a corporate re-organization, merger or amalgamation, or the sale of all or substantially all of our assets, provided that, where appropriate, any party to whom the information is disclosed is bound by agreements or obligations, and required to use or disclose Your personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless You consent otherwise; or
  • CP may share Your personal information with service providers who perform services on our behalf. For example, we may hire other companies to handle the processing of payments, collect debts, to provide data storage, to host websites, to fulfill orders, to assist in direct marketing, to conduct audits, etc. Those companies will be permitted to obtain only the personal information they need only as necessary to provide services to us. Each company is bound by agreement or obligations with CP to implement and maintain reasonable security procedures and practices in order to use and disclose Your personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless You consent otherwise. We take all reasonable measures and precautions to protect Your personal information when it is being handled by our service providers.


How to Opt-Out / Withdraw Consent

You can withdraw Your consent for the use of Your personal information at any time by requesting the deletion of Your Account or by providing written notice to us of that withdrawal.  However, You acknowledge that information may be retained by CP for audit or archival purposes or as required by applicable federal, state and provincial laws. You can also review and update Your personal information yourself through the user features in Your account.
 

Other measures we take to safeguard your information

  • Use state of the art encryption technologies to protect PII (Personal Identifiable Information)
  • Put firewalls and other technical security measures in place on hardware to prevent unauthorized access to PII stored in the database
  • Put access controls in place in the software to prevent users from accessing PII of other users unless explicitly authorized
  • Ensure user consent for any sensitive PII collected

 

Retention of Personal Information

CP maintains information about You for as long as we provide services to You, and for as long as it remains necessary for identified purposes or as required by law which may extend beyond the termination of our relationship with You. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law. All retained personal information will remain subject to the terms of this Privacy Policy. If You request that Your name be removed from our databases, it may not be possible to completely delete all Your Personal Information due to technological and legal constraints. However, we will take such steps as are reasonable to destroy the information or to ensure that the information is de‑identified.

 

Compliance with the Family Education Rights & Privacy Act (FERPA)

In the United States, the Family Educational Rights & Privacy Act, 20 U.S.C. § 1232(g), restricts the disclosure of personally identifiable information from a student’s education records, unless an exception applies. For U.S. users, CP’s data protection and privacy policies and practices comply with FERPA and other applicable federal and state education privacy laws. CP maintains the confidentiality of FERPA-covered student data, and only uses this information to deliver and improve CP Services provided to schools and their students, as provided in CP’s agreements with schools.  



GATHERING, USE AND DISCLOSURE OF NON-PERSONALLY-IDENTIFYING INFORMATION

 

What is non-personally-identifying information

“Non-Personally-Identifying Information” is information that, without the aid of additional information, cannot be directly associated with a specific person. “Personally-Identifying Information,” by contrast, is information such as a name or email address that, without more, can be directly associated with a specific person. Like most website operators, CP gathers from users of the Website Non-Personally- Identifying Information of the sort that Web browsers, depending on their settings, may make available. That information includes the user’s Internet Protocol (IP) address, operating system, browser type and the locations of the websites the user views right before arriving at, while navigating and immediately after leaving the Website. Although such information is not Personally-Identifying Information, it may be possible for CP to determine from an IP address a user’s Internet service provider and the geographic location of the visitor’s point of connectivity as well as other statistical usage data. CP analyzes Non-Personally-Identifying Information gathered from users of the Website to help CP better understand how the Website is being used. By identifying patterns and trends in usage, CP is able to better design the Website to improve users’ experiences, both in terms of content and ease of use. From time to time, CP may also release the Non-Personally-Identifying Information gathered from Website users in the aggregate, such as by publishing a report on trends in the usage of the Website.

Web Cookies

A “Web Cookie” is a string of information which assigns you a unique identification that a website stores on a user’s computer, and that the user’s browser provides to the website each time the user submits a query to the website. We use cookies on the Website to keep track of services you have used, to record registration information regarding your login name and password, to record your user preferences, to keep you logged into the Website and to facilitate purchase procedures. CP also uses Web Cookies to track the pages that users visit during each Website session, both to help CP improve users’ experiences and to help CP understand how the Website is being used. As with other Non- Personally-Identifying Information gathered from users of the Website, CP analyzes and discloses in aggregated form information gathered using Web Cookies, so as to help CP, its partners and others better understand how the Website is being used. CP USERS WHO DO NOT WISH TO HAVE WEB COOKIES PLACED ON THEIR COMPUTERS SHOULD SET THEIR BROWSERS TO REFUSE WEB COOKIES BEFORE ACCESSING THE WEBSITE, WITH THE UNDERSTANDING THAT CERTAIN FEATURES OF THE WEBSITE MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF WEB COOKIES. WEBSITE USERS WHO REFUSE WEB COOKIES ASSUME ALL RESPONSIBILITY FOR ANY RESULTING LOSS OF FUNCTIONALITY.

Web Beacons

A “Web Beacon” is an object that is embedded in a web page or email that is usually invisible to the user and allows website operators to check whether a user has viewed a particular web page or an email. CP may use Web Beacons on the Website and in emails to count users who have visited particular pages, viewed emails and to deliver co-branded services. Web Beacons are not used to access users’ Personally-Identifying Information. They are a technique CP may use to compile aggregated statistics about Website usage. Web Beacons collect only a limited set of information, including a Web Cookie number, time and date of a page or email view and a description of the page or email on which the Web Beacon resides. You may not decline Web Beacons. However, they can be rendered ineffective by declining all Web Cookies or modifying your browser setting to notify you each time a Web Cookie is tendered, permitting you to accept or decline Web Cookies on an individual basis.

Analytics

We may partner with selected third parties to allow tracking technology on the Website, which will enable them to collect data about how you interact with the Website and our services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity.

Mobile Device Additional Terms

• Mobile Device. If you use a mobile device to access the Website or download any of our applications, we may collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.

• Geo-Location Information. Unless we have received your prior consent, we do not access or track any location-based information from your mobile device at any time while downloading or using our mobile application or our services, except that it may be possible for CP to determine from an IP address the geographic location of your point of connectivity, in which case we may gather and use such general location data.

• Mobile Analytics. We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information, such as how often you use the application, the events that occur within the application, aggregated usage, performance data and where the application was downloaded from. We do not link the information we store within the analytics software to any Personally-Identifying Information you submit within the mobile application.


SECURITY

We take the security of your Personally-Identifying Information seriously and use reasonable electronic, personnel and physical measures to protect it from loss, theft, alteration or misuse. However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized persons will view your information. We are not responsible for third-party circumvention of any privacy settings or security measures.

We are dedicated to protect all information on the Website as is necessary. However, you are responsible for maintaining the confidentiality of your Personally-Identifying Information by keeping your password confidential. You should change your password immediately if you believe someone has gained unauthorized access to it or your account. If you lose control of your account, you should notify us immediately.

PRIVACY POLICY CHANGES

CP may, in its sole discretion, change this Privacy Policy from time to time. Any and all changes to CP’s Privacy Policy will be reflected on this page and the date new versions are posted will be stated at the top of this Privacy Policy. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account. Users should regularly check this page for any changes to this Privacy Policy. CP will always post new versions of the Privacy Policy on the Website. However, CP may, as determined in its discretion, decide to notify users of changes made to this Privacy Policy via email or otherwise. Accordingly, it is important that users always maintain and update their contact information.

CHILDREN

The Children's Online Privacy Protection Act ("COPPA") protects the online privacy of children under 13 years of age. We do not knowingly collect or maintain Personally-Identifying Information from anyone under the age of 13, unless or except as permitted by law. Any person who provides Personally- Identifying Information through the Website represents to us that he or she is 13 years of age or older. If we learn that Personally-Identifying Information has been collected from a user under 13 years of age on or through the Website, then we will take the appropriate steps to cause this information to be deleted. If you are the parent or legal guardian of a child under 13 who has become a member of the Website or has otherwise transferred Personally-Identifying Information to the Website, please contact CP using our contact information below to have that child's account terminated and information deleted.

CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about the Personally-Identifying Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of the Personally-Identifying Information that was shared and the names and addresses of all third parties with which we shared Personally-Identifying Information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to our privacy officer as listed below.

DO-NOT-TRACK POLICY

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. Because there is not yet a common understanding of how to interpret the DNT signal, the Website currently does not respond to DNT browser signals or mechanisms.

CONTACT

If you have any questions regarding our Privacy Policy, please contact our Privacy Officer at:

ClassPulse
Attn: Privacy Officer
11 E 29th St.
New York, NY 10016
Email: contact@classpulse.org Phone: (917) 691-6416