Last Updated: May 1, 2018
GATHERING, USE AND DISCLOSURE OF NON-PERSONALLY-IDENTIFYING INFORMATION
Application of This Policy
What is Personal Information
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:
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);
Assist us in creating, improving, or providing content that is relevant to You;
Assist us in creating better products and services to meet the needs of Institution/Faculty;
Allow You to purchase and download products, obtain access to the System or otherwise engage in activities You select;
Provide You with technical support;
Help You quickly find software, services or product information important to Institutions/Faculty;
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
- 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.
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
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.
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.
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.
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.
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.
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.
Attn: Privacy Officer
11 E 29th St.
New York, NY 10016
Email: email@example.com Phone: (917) 691-6416